IHTM30212 - Transfers on death: categories of qualifying property
The categories are:
land (IHTM30213)
from 6 April 2026, property which qualifies for business relief (BR) (IHTM25131) (see below)
businesses (IHTM30214)
shares: control holdings (IHTM30217)
unquoted shares: undue hardship (IHTM30218)
unquoted shares: 20% tax test (IHTM30219)
unquoted shares: £20,000 value and 10% nominal value test (IHTM30220).
The following pages provide detailed instructions on their treatment.
Property which qualifies for BR
From 6 April 2026:
there is a 100% relief allowance (IHTM25500) for the combined value of qualifying business and agricultural property, and the value over that amount gets relief at 50%
additionally, shares in companies listed on a market that does not meet the definition of ‘listed’ for HMRC purposes (such as AIM), can now only qualify for 50% relief if the conditions are met (IHT25301).
From the same date, any property which qualifies for BR will also qualify for instalments. Those instalments will be interest free (IHTM30363) - see IHTA/S227(2)(aa) and IHTA/S234(1)(a)).
If property qualifies for BR at 100%, either because the transfer was before 6 April 2026 or, after that, because it is covered by the 100% relief allowance, then instalments will not be relevant.