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HMRC internal manual

Inheritance Tax Manual

Stocks and shares: unlisted shares: unlisted securities

Loan capital is not part of the issued share capital of the company but is part of the company’s borrowing. Unlike bank overdrafts, or other types of borrowing from banks and financial institutions, loan capital may be held by individuals and can be bought and sold in the same way as shares. 

  • Each type of loan capital is a form of security. 
  • The security may be in the form of a debenture or Loan Stock/Notes. 

Business relief

Securities do not usually qualify for business relief (IHTM25131) unless the transferor has control of the company.