SVM108290 - Inheritance Tax: Close Companies - Claims under ss.94 - 102 IHTA 1984 generally

Experience has shown that substantial claims tend to arise when almost all the shares are owned by one person (or by spouses). Particular attention should therefore be paid to transactions by “one man” companies.

It is important to note that any such alterations are not PETs.

If, the Team Leader’s advice having been sought, there appears (on the face of it) to be a claim and the matter is worth pursuit (having regard to the tax threshold and so on) you should notify IHT Compliance of the claims for tax.

Once a claim is established and the general basis of valuation agreed, the case may continue to be worked normally.

Additional Guidance: VM150000