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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Unlisted shares: Sale within three years of death

If the transfer occurred on a death, IHTA84/S122 (2) provides that relief will not be due in respect of any holdings

  • sold within three years after the death
  • where the shares are sold and revalued as a minority holding under IHTA84/S176.

This means relief will not be due unless the holding, by itself, would have been sufficient to give control immediately before the death. In these circumstances, you may need to withdraw any relief already given. However, where the relief is at 100% it is unlikely that a claim under IHTA84/S176 will be made.