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Except as otherwise provided by FA 2004, Sch 15, the value of any property shall for the purposes of that Schedule be the price which the property might reasonably be expected to fetch if sold in the open market at that time; but that price shall not be assumed to be reduced on the ground that the whole property is to be placed on the market at one and the same time¹.

This is the same as the 'market value' provision for inheritance tax purposes².

In relation to any land, chattel or intangible property, the 'valuation date' is prescribed by the regulations and is 6 April in the relevant year of assessment or, if later, the first day of the 'taxable period'³.

There is no statutory requirement that independent valuers be used. However, HMRC 'expect the chargeable person to take all reasonable steps to ascertain the valuations, as they would do if, for example, they were looking to let a property on the open market'⁴. Clearly, not obtaining a professional valuation