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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Lifetime transfers: specific lifetime reliefs: fall in value relief: portfolio of assets

When a number of assets are transferred on the same occasion, such as a portfolio of shares and cash when a interest in a trust comes to an end, allow relief on the individual assets which have fallen in value.

Do not net off the gains and losses for the whole portfolio (as you would for loss on sale of shares relief (IHTM34001)).

Where there is more than one sale disposing of the underlying assets, see the instructions at IHTM14630.

If the taxpayer queries this approach, refer to Technical.