The date of death or probate value automatically forms the base value on a subsequent disposal for capital gains tax (CGT) purposes but only if it has been ‘ascertained’ for inheritance tax (IHT) purposes within the meaning of TCGA 1992, section 274.

In a non-IHT paying estate the value will not normally be ascertained in the technical sense and it would be open for the taxpayer to argue a different base value. If a property is sold subsequently for a higher figure than that submitted it may be that the sale price reflects the market value at the date of death, or it may be that there has been an increase in the value since that date.