SolvedCH122340 | Offshore matters: asset-based penalties: identification and valuation of assets: inheritance tax
From HM Revenue & Customs · Compliance Handbook
Where the principle tax at stake, see CH122310, is inheritance tax the following values will be used to calculate the asset-based penalty
the asset is the property which has been transferred and subsequently given rise to inheritance tax.
the value of this property will be the value used by HMRC in assessing the liability to inheritance tax.
For further guidance on this, see IHTM09701.