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HMRC internal manual

Inheritance Tax Manual

Interest in part of a fund: value of a share

The importance of IHTA84/S50 (5) is that it ensures that the beneficiary’s interest is valued as a fraction of the whole, with no question of joint property discount (IHTM15071).

The share to be valued (IHTM16101) on a termination in lifetime depends upon whether the claim is on -

  • the termination of all of that beneficiary’s interest, or
  • the termination of part of that beneficiary’s interest - IHTA84/S52 (4)

On a claim on a death the termination necessarily relates to the entire share in which the beneficiary had an interest and that share is to be valued.