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Contents

Official guidance
Inheritance Tax Manual

IHTM25000 · Business relief and businesses

  • IHTM25001 · Introduction
  • IHTM25011 · Investigating business relief and businesses: Introduction
  • IHTM25012 · Investigating business relief and businesses: Reviewing form IHT413 or D38
  • IHTM25021 · Investigation in 100% relief cases: Introduction
  • IHTM25051 · Valuing businesses and partnerships: What is a business?
  • IHTM25052 · Valuing businesses and partnerships: Business accounts
  • IHTM25053 · Valuing businesses and partnerships: liabilities - restricted reductions
  • IHTM25060 · Valuing businesses and partnerships: Business terms
  • IHTM25081 · Valuing the business: Investigating the profit and loss account
  • IHTM25082 · Valuing the business: Investigating the balance sheet
  • IHTM25083 · Valuing the business: Adjusting the capital account
  • IHTM25091 · What is a partnership: Introduction
  • IHTM25092 · What is a partnership: Investigating partnership deeds
  • IHTM25093 · What is a partnership: Cases where there are no deeds
  • IHTM25094 · What is a partnership: Limited liability partnerships
  • IHTM25101 · Valuing the partnership interest: Introduction
  • IHTM25102 · Valuing the partnership interest: Partnership share
  • IHTM25103 · Valuing the partnership interest: The balance sheet
  • IHTM25104 · Valuing the partnership interest: Freehold and leasehold property
  • IHTM25105 · Valuing the partnership interest: Agricultural land tenanted by a partnership
  • IHTM25106 · Valuing the partnership interest: Agricultural land owned by deceased and occupied by a partnership
  • IHTM25108 · Valuing the partnership interest: Goodwill
  • IHTM25109 · Valuing the partnership interest: Livestock
  • IHTM25110 · Valuing the partnership interest: Other assets
  • IHTM25111 · Valuing the partnership interest: Sales
  • IHTM25112 · Valuing the partnership interest: Income Tax
  • IHTM25120 · Valuing businesses and partnerships: Fetters
  • IHTM25121 · Valuing Businesses and Partnerships: Relationship between Business and Agricultural relief
  • IHTM25122 · Valuing Businesses and Partnerships: Instalments
  • IHTM25123 · Valuing Businesses and Partnerships: Partnerships and lifetime transfers
  • IHTM25131 · Business relief: Outline of business relief
  • IHTM25141 · Relevant Business Property: Investigating Relevant Business Property
  • IHTM25151 · Business interests: Rate of relief
  • IHTM25152 · Business interests: Property consisting of a business or a business interest
  • IHTM25153 · Business interests: Meaning of “business”
  • IHTM25154 · Business interests: Settled property
  • IHTM25171 · Unquoted securities - control holding: Securities within S105(1)(b)
  • IHTM25172 · Unquoted securities - control holding: When is the transferor required to have control?
  • IHTM25191 · Other holdings of unquoted shares: Rate of relief
  • IHTM25192 · Other holdings of unquoted shares: Meaning of unquoted for business relief purposes
  • IHTM25193 · Other holdings of unquoted shares: American Depositary Receipts
  • IHTM25201 · Control holdings of quoted shares or securities: Rate of relief
  • IHTM25202 · Control holdings of quoted shares or securities: Transfers and shares within IHTA84/S105 (1)(cc)
  • IHTM25221 · Land and buildings, machinery and plant: Rate of relief
  • IHTM25222 · Land and buildings, machinery and plant: Property within IHTA84/S105 (1)(d)
  • IHTM25223 · Land and buildings, machinery and plant: Additional user requirement
  • IHTM25224 · Land and buildings, machinery and plant: Transferor's interest in the occupying company or partnership
  • IHTM25225 · Land and buildings, machinery and plant: Property used by a partnership
  • IHTM25226 · Land and buildings, machinery and plant: Settled property
  • IHTM25227 · Land and buildings, machinery and plant: Machinery or plant
  • IHTM25241 · Settled property used in the life tenant's business: Rate of relief
  • IHTM25242 · Settled property used in the life tenant's business: Property within IHTA84/S105 (1)(e)
  • IHTM25243 · Settled property used in the life tenant's business: Scope of IHTA84/S105 (1)(e) in practice
  • IHTM25250 · Other relevant business property: Partnership interests
  • IHTM25251 · Other relevant business property: Woodlands syndicates
  • IHTM25252 · Other relevant business property: Agri-environment schemes
  • IHTM25253 · Other relevant business property: Land used under the Woodland and Peatland Carbon Codes
  • IHTM25261 · Investment businesses: Introduction
  • IHTM25262 · Investment businesses: Exceptions
  • IHTM25263 · Investment businesses: Holding companies
  • IHTM25264 · Investment businesses: Holding company and LLP examples
  • IHTM25265 · Business relief: Investment businesses: Wholly or mainly
  • IHTM25266 · Business relief: Investment businesses: Property based businesses
  • IHTM25271 · Business relief: Investment businesses: Property letting
  • IHTM25272 · Business relief: Investment businesses: Property consisting of a business
  • IHTM25273 · Business relief: Investment businesses: Meaning of 'investment'
  • IHTM25274 · Business relief: Investment businesses: Land as a business asset
  • IHTM25275 · Business relief: Investment businesses: Lettings of commercial premises
  • IHTM25276 · Business relief: Investment businesses: Furnished lettings
  • IHTM25277 · Business relief: Investment businesses: Hotels, Bed and Breakfast, Residential Homes, and other accommodation
  • IHTM25278 · Business relief: Investment businesses: Holiday lettings
  • IHTM25279 · Business relief: Investment businesses:Caravan sites
  • IHTM25280 · Business relief: Investment businesses: Other lettings
  • IHTM25291 · Contracts for sale: Introduction
  • IHTM25292 · Contracts for sale: Shareholdings and partnership interests
  • IHTM25301 · The ownership test: Introduction
  • IHTM25302 · The ownership test: Meaning of ownership
  • IHTM25303 · The ownership test: Changes in the nature of the business
  • IHTM25310 · Business relief: Replacement property: Introduction
  • IHTM25311 · Business relief: Replacement property: Conditions
  • IHTM25313 · Business relief: Replacement property: Limitation of relief
  • IHTM25314 · Business relief: Replacement property: Minority holdings of unquoted shares
  • IHTM25321 · Successions: Introduction
  • IHTM25331 · Successive transfers: Introduction
  • IHTM25333 · Successive transfers: Limitation of relief
  • IHTM25341 · Assets excluded from relief: Introduction
  • IHTM25342 · Assets excluded from relief: Assets not used in the business
  • IHTM25351 · Excepted assets: Introduction
  • IHTM25352 · Excepted assets: Future use
  • IHTM25353 · Excepted assets: Assets used for personal benefit
  • IHTM25354 · Excepted assets: Part business use of land or buildings
  • IHTM25361 · Lifetime transfers - additional conditions: Introduction
  • IHTM25363 · Lifetime transfers - additional conditions: The two conditions
  • IHTM25364 · Lifetime transfers - additional conditions: Continuing ownership
  • IHTM25365 · Lifetime transfers - additional conditions: Remaining business property
  • IHTM25366 · Lifetime transfers - additional conditions: Transfers of shares and securities
  • IHTM25367 · Lifetime transfers - additional conditions: The transferee
  • IHTM25368 · Lifetime transfers - additional conditions: Failure to satisfy the conditions
  • IHTM25369 · Lifetime transfers - additional conditions: Replacement property
  • IHTM25370 · Lifetime transfers - additional conditions: Replacement property (additional rule for shares or securities)
  • IHTM25381 · Gifts with reservation: Introduction
  • IHTM25382 · Gifts with reservation: Notional transfer
  • IHTM25383 · Gifts with reservation: Rate of relief on shares or securities
  • IHTM25384 · Gifts with reservation: Replacement property
  • IHTM25500 · AR/BR 100% relief allowance: Section Overview
  • IHTM25510 · AR/BR 100% relief allowance: overview
  • IHTM25520 · AR/BR 100% relief allowance: individuals
  • IHTM25521 · AR/BR 100% relief allowance: individuals - transitional provisions
  • IHTM25522 · AR/BR 100% relief allowance: individuals - interests in possession within IHTA84/S49
  • IHTM25523 · AR/BR 100% relief allowance: individuals – apportionment – more than one chargeable transfer
  • IHTM25524 · AR/BR 100% relief allowance: individuals – apportionment – different titles of the estate on death
  • IHTM25530 · AR/BR 100% relief allowance: transfer of unused allowance
  • IHTM25531 · AR/BR 100% relief allowance: transfer of unused allowance – basic principles
  • IHTM25532 · AR/BR 100% relief allowance: transfer of unused allowance- focus is on extent to which the 100% relief allowance is unused 
  • IHTM25533 · AR/BR 100% relief allowance: transfer of unused allowance - how to make the claim
  • IHTM25534 · AR/BR 100% relief allowance: transfer of unused allowance – time limits for claim
  • IHTM25535 · AR/BR 100% relief allowance: transfer of unused allowance - claims by people other than the personal representatives
  • IHTM25536 · AR/BR 100% relief allowance: transfer of unused allowance- reviewing form IHT 437
  • IHTM25537 · AR/BR 100% relief allowance: transfer of unused allowance - how the amount to be transferred is calculated
  • IHTM25538 · AR/BR 100% relief allowance: transfer of unused allowance - calculation where there is a lifetime transfer
  • IHTM25539 · AR/BR 100% relief allowance: transfer of unused allowance – calculation where the survivor has been married to more than one spouse or been in more than one civil partnership  
  • IHTM25540 · AR/BR 100% relief allowance: transfer of unused allowance - calculation where the survivor was married to, or in a civil partnership with, someone who was entitled to 100% transferable allowance where no claim was made on the earlier death
  • IHTM25541 · AR/BR 100% relief allowance: transfer of unused allowance - simultaneous deaths
  • IHTM25550 · APR/BPR 100% relief allowance: settlements - overview
  • IHTM25551 · APR/BPR 100% relief allowance: settlements - “pre-commencement settlements”
  • IHTM25552 · AR/BR 100% relief allowance: settlements - relevant property settlements
  • IHTM25553 · AR/BR 100% relief allowance: settlements - transitional period - temporary relaxation of ownership and occupation conditions
  • IHTM25554 · AR/BR 100% relief allowance: settlements - special trusts (other than age 18-to-25 trusts)
  • IHTM25555 · AR/BR 100% relief allowance: settlements - 18-25 trusts
  • IHTM25570 · AR/BR: 50% rate – unlisted shares and securities
  • IHTM25580 · AR/BR 50% rate: instalment option
  • IHTM25022 · Investigation in 100% relief cases: Business interests - chart for relief on death
  • IHTM25023 · Investigation in 100% relief cases: Business interests - chart for relief on potentially exempt transfers
  • IHTM25024 · Investigation in 100% relief cases: Business interests - chart for relief on chargeable lifetime transfers
  • IHTM25107 · Valuing the partnership interest: Milk quotas
  • IHTM25113 · Valuing the partnership interest: Adjusting the deceased's capital account
  • IHTM25312 · Replacement property: chart
  • IHTM25322 · Successions: chart
  • IHTM25332 · Successive transfers: chart
  • IHTM25362 · Lifetime transfers - additional conditions: chart
  1. Business relief and businesses: Contents
  2. Valuing the business: Investigating the balance sheet

IHTM25082 | Valuing the business: Investigating the balance sheet

From HM Revenue & Customs · Inheritance Tax Manual

The balance sheet is your main source of information about the value of the business assets and liabilities at the date of death/transfer.

If business relief (IHTM25131) is due at 100% in full you will only need to check whether any assets should be excluded from qualifying for relief (IHTM25341).

If business relief (IHTM25131) at 100% is not available in full you will need to consider each item shown in the balance sheet and decide whether it warrants further investigation. You can call on specialists, such as the Valuation Office Agency (VOA) (IHTM23002), to help where necessary.

Remember that 100% relief will be limited to a maximum of £2.5m (or possibly up to £5m with transfer of unused allowance from a spouse or civil partner) from 6 April 2026 (IHTM25500).

You should check through the business assets and liabilities and ensure that the open market value is included. In this way you are simply valuing the assets of the business on the assumption that it came to an end on the deceased’s death. Some businesses, however, are sold as a going concern and the sale value may be offered as the date of death value. If the sale price is offered you should question the reasons for this.

Sale values of individual assets can normally be accepted (subject to any checks, e.g. in respect of land and buildings) if the sale took place shortly after the death.

Freehold and Leasehold Property

Refer the values noted to the VOA in the normal way. If agricultural relief has been claimed send form IHT414 (IHTM24255) unless this has already been done, and see if relief is due before referring.

Most businesses require premises from which to operate. It may of course operate from rented property in which case you would expect to find a deduction for rent in the profit and loss account. In such cases details of the tenancy should be obtained as it may have a capital value which should be included as an asset.

As regards leasehold property, if the unexpired term at the date of death is a very short period only it may have a modest market value which may not require reference to the VOA.

Fixed Assets

Fixed assets can include plant and machinery, motor vehicles, office and business equipment, fixtures and fittings. Improvements to property may also be shown in fixed assets.

You should ensure that the values shown fully reflect open market values. The figure shown is usually the cost less depreciation, or book value. You may wish to check if the figure looks unexpectedly high or low.

Current Assets

In most cases you can accept the figure shown because it shows what those assets cost to purchase or their current market value.

It should be possible from most balance sheets to compare the current year’s figures with the previous year’s. This should help you decide if the current figures look odd in any way.

Land – if land is a current asset then a reference to the VOA is required.

  • Sundry debtors (book debts)- this reflects the amount of money owed to the business.

  • Stock/work in progress

  • Pre-payments or payments in advance- these represent cash paid for insurances, rent, business rates etc. for a period not covered by the current accounts.

  • Investments

You should check if there are any investments which were not used in the business (IHTM25341).

Bank and Building Society accounts will be included at their capital value, and any interest will be shown in the profit and loss account.

  • Cash items

Accept without query.

  • Goodwill

You will rarely find a value for this shown in the balance sheet because a calculation of its value is not required until the business as a whole is being valued. If goodwill is shown it will often be purchased goodwill that is being written off and not the value of the goodwill of the whole business.

No goodwill exists for farming or NHS medical practices.

Refer the investigation of goodwill to SAV. When referring the case you should state the type of business involved as different SAV teams specialise in different types of business.

In some businesses ‘inherent’ goodwill is attached to the land and buildings used in the business and the VOA will include its value in the value of the property. In the following cases the valuation of such goodwill is conducted wholly by the VOA:

  • licenced premises

  • breweries

  • hotels

  • restaurants

  • cinemas

  • theatres

  • mineral undertakings

  • brickworks.

The valuation of any other goodwill element in respect of the above businesses is for SAV.

Liabilities

  • Mortgages

Ensure that the amount shown accurately reflects the sum outstanding at the date of death and see if there was a mortgage protection policy if worth.

In cases where only part of the business land (IHTM25354) qualifies for business relief ensure that the mortgage is apportioned, if necessary, between all the properties on which it was charged and, where only part of a single property qualifies, between the relievable and non-relievable portions.

  • Sundry creditors

These are the sums owed by the business. The provisions of IHTA84/S162 have to be satisfied before a deduction is allowed. If a large amount, in the context of the business as a whole, is involved or the amount suddenly increased in the last year, you should call for a schedule of the liabilities as at the date of the balance sheet and consider further.

  • Overdrafts

Normally these can be accepted.

  • Arrears of wages due to relatives

There has to have been a contract of employment (which need not have been in writing) before this can be allowed. You should consider whether the amount involved warrants further investigation and, if so, call for further details of the agreement in order to confirm that there was a contractual liability.

  • Income Tax and CGT

If these appear as a liability they should be excluded as they are personal not business liabilities.

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