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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Lifetime transfers - additional conditions: Transfers of shares and securities

In respect of deaths on or after 6 April 1996, the second condition does not have to be satisfied for lifetime transfers of:


  • shares which were quoted at the time of the transfer
  • any unquoted shares;
  • unquoted securities, which either by themselves or together with other such securities owned by the transferor and any unquoted shares so owned, gave the transferor control.

Any change in the company’s activities is not relevant. What matters is that if the shares were unquoted at the date of transfer they remain unquoted at the date of death.

Further details can be found in the Shares and Assets Valuation Manual at (SVM111260) .