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HMRC internal manual

Inheritance Tax Manual

Unquoted securities - control holding: When is the transferor required to have control?

Under IHTA84/S105 (1)(b) the transferor is required to have had control only immediately before the transfer and not during any earlier period. However, the ownership test (IHTM25301) still applies so that any securities acquired by the transferor within two years of the transfer will not qualify for relief unless by virtue of the provisions for replacement property (IHTM25311), successions (IHTM25321) or successive transfers (IHTM25331).