IHTM30442 | Reconsideration by HMRC: agreements

From HM Revenue & Customs · Inheritance Tax Manual

An agreement may be either

  • a specific statement by this office that a value has been accepted, or

  • the acceptance by the taxpayers of a value put forward by HMRC - e.g. a Valuation Office Agency (VOA) () increase notified to the taxpayers and accepted by them.

You must regard an agreement on the value of the property as a bar to seeking to reopen the valuation to establish a higher value unless new material information () is received. In certain circumstances this can include sales ().

The operative date for considering whether there is a bar to reopening is the date of acceptance, whether by this office or by the taxpayers - the date of assessment or payment of any additional tax consequential on the agreed value is immaterial.