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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Interest in unadministered estates: effect on reliefs


Where business (IHTM25131) or agricultural relief (IHTM24001) is available against assets in an unadministered estate (IHTM22011) with regard to the qualifying period for ownership, you must treat the beneficiary as having owned the assets from the date of death of the person whose estate is unadministered (IHTA84/S108(a) and S120(1)(a) respectively). If the asset was inherited from a spouse or civil partner the period that the spouse or civil partner owned the asset is also taken into account by IHTA84/S108(b) and S120(1)(b) respectively.