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HMRC internal manual

Inheritance Tax Manual

Dispositions not intended to confer bounty: IHTA84/S10 qualified or excluded

The application of IHTA84/S10 (1) is qualified or excluded if the transaction involves two types of property.

Unquoted sharesIHTA84/S10 (1) does not apply to a sale of unquoted shares (

IHTM18131) or debentures (IHTM18280) unless it is shown that the sale was

  • at a price freely negotiated at the time of the sale, or
  • at a price such as might be expected to have been freely negotiated at the time of the sale.Any transaction concerning the sales of unquoted shares or debentures where the provisions of IHTA84/S10 are in point is the responsibility of SAV. You should refer any such case to SAV at an early stage.

Reversionary interestsIHTA84/S10 (1) does not apply to a disposition (

IHTM04023) by which

  • a person who is entitled to an interest (whether in possession or not) in any settled property
  • acquires a reversionary interest expectant (whether immediately or not) on that interest.Consequently, the disposition will normally be a transfer of value (

IHTM04024) see IHTM04282.