Taxation of Chargeable Gains Act 1992 section 274

Value determined for inheritance tax

Section 274 ensures that where the value of an asset has already been established for inheritance tax purposes on a person's death, that same value is used as the market value for capital gains tax purposes.

• When inheritance tax is chargeable on a deceased person's estate, any asset value already determined for IHT purposes is automatically adopted as the market value for CGT at the date of death.
• This applies whether the value was agreed formally in proceedings or through any other means, and regardless of whether the agreement was unconditional or made on a without-prejudice basis.
• The rule applies even where the asset was valued as part of a larger holding under the estate concept or the related property provisions for IHT purposes.
• The effect is to prevent disputes or inconsistencies arising from different valuations being used for IHT and CGT on the same asset at the same date of death.