Commentary

I8.242A Valuation under the related property rules

IHT, trusts and estates

I8.242A Valuation under the related property rules

I8.242A Valuation under the related property rules

Where the value of any property comprised in a person's estate including property in which he has a beneficiary-taxed interest in possession (for its meaning, see I5.201) under any settlement would be less than his proportion (known as the 'appropriate portion') of the value of that and any related property combined into one holding, the higher value applies1. The value which is apportioned is the value of the two properties if sold together, not the values of the two valued separately and added together2. Where property other than shares of the same class in a company is concerned, the appropriate portion of the value of the combined holding is determined according to the relationship of the separate values3. This can be expressed as a formula:

the transferor's portion =

where:

  1.  

         V is the value of the transferor's portion of the property;

  2.  

         TV is the total of the transferor's portion and the related portion valued separately; and

  3.  

         CV is the value of both these portions valued as one combined property.

Example 1

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