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HMRC internal manual

Inheritance Tax Manual

Foreign property: specific British Government Securities: exempt securities as partnership assets

Very occasionally the assets of a partnership may include exempt securities which will normally constitute ‘excepted assets’ (see IHTA84/S112) so they will not qualify for Business Relief. In this situation a partner’s transfer of their interest in the partnership will be excluded property:

  • to the extent that it is attributable to the exempt securities (IHTM27241)
  • and only if it satisfies the conditions specified for the security

You should calculate the amount to be excluded as follows:

(Value of exempt securities ÷ Total value of partnership) × Value of transferor’s partnership interest