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HMRC internal manual

Inheritance Tax Manual

Sales of related property, etc: no connection between vendor and purchaser

The sale will not qualify for relief if the person concerned as vendor or having an interest in the proceeds of the sale is connected with any person as purchaser or having an interest in the purchase, IHTA84/S176 (3)(c). In other words you should disqualify any sale where there is a connection between any persons concerned or interest on either side in either a fiduciary or a beneficial capacity.

The term ‘persons having an interest in’ the proceeds of sale or the purchase will include the beneficiaries under a Will or settlement where the vendors or purchasers are the personal representatives or trustees.