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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Contracts for sale: Introduction

Property subject to a binding contract for sale is not relevant business property (IHTM25141) except where it is:

  • a business or an interest in a business and the sale is to a company which is to carry on the business and is made wholly or mainly in consideration of shares in or securities of that company, or
  • shares in or securities of a company, and the sale is made for the purposes of reconstruction or amalgamation, IHTA84/S113. Where a lifetime transfer (other than a potentially exempt transfer (

IHTM04057) is made shortly before a sale, you should investigate the circumstances (IHTM14832) to ensure the relief is properly due.