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HMRC internal manual

Inheritance Tax Manual

Control holdings of quoted shares or securities: Transfers and shares within IHTA84/S105 (1)(cc)

IHTA84/S105(1)(cc) applies to transfers and other events occurring on or after 10 March 1992.

It applies to quoted shares or securities which

  • either by themselves or together with other such shares or securities owned by the transferor
  • gave the transferor control of the company immediately before the transfer.

The following instructions on IHTA84/S105 (1)(b) also apply to IHTA84/S105 (1)(cc):

the shares and securities within IHTA84/S105 (1)(b) (IHTM25171), and
the time at which the transferor is required to have control (IHTM25172)

Shares and Assets Valuation (SAV) will advise whether a holding of shares or securitiess atisfies the requirements of IHTA84/S105 (1)(cc) but may not be able to indicate whether or not business relief is due.