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HMRC internal manual

Inheritance Tax Manual

Lifetime transfers: Where shares or securities are the ‘original property’

Where the property transferred is shares or securities in a company, the value transferred is treated as attributable to the agricultural value (IHTM24150) of agricultural property (IHTM24030) if

  • the agricultural property forms part of the company assets and part of the value of the shares or securities can be attributed to the agricultural value of agricultural land, IHTA84/S122 (1)(a) and
  • the shares or securities gave the transferor control of the company (IHTM24124) immediately before the transfer, IHTA84/S122 (1)(b).

Where the original property consists of shares that fall within the provisions of IHTA84/S122 (1), the first two of the additional conditions (IHTM24173) continue to apply, but the third and fourth conditions are replaced by the requirement that the agricultural property within IHTA84/S116 and IHTA84/S122 (1) was owned by the company and occupied (by the company or another) for agricultural purposes.