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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Tax burden on death: equal beneficiaries, unequal benefits

If there are several beneficiaries, the first transfer may increase their estates in different proportions even though they take equally.

For example, Cyril dies leaving 90 shares in XYZ Ltd equally between his three children, Dominic, Simon and Julia, along with the rest of his estate. Dominic already owns 80 shares in XYZ Ltd. The total number of shares in the company is 200. Adding the 30 shares he receives from Cyril gives Dominic a control holding in XYZ Ltd. Because of this Dominic’s estate is increased by a larger amount than Simon and Julia’s estates who owned no shares before Cyril died.

Nonetheless in these circumstances the tax is attributed equally.