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HMRC internal manual

Inheritance Tax Manual

Transfers on death: control holdings of shares and securities

Shares or securities, whether quoted or unquoted, of a company which gave the deceased control of the company immediately before his death are qualifying property for instalments.

‘Control’ is defined by IHTA84/S269. The definition was considered in the High Court in Walding and others v IRC [1996] STC 13, and the effect of a casting vote was considered in Walker, Fanny (deceased, executors of) v IRC (2001) SpC 275.

Shares and Asset Valuation will advise whether a holding qualifies for instalments under IHTA84/S228 (1)(a).