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HMRC internal manual

Inheritance Tax Manual

Transfers and other events on or after 17 March 1987: unquoted shares

For tax attributable to unquoted shares or securities, instalments are available only if the shares or securities remained unquoted (IHTM30216) throughout the period from the date of the chargeable transfer to the death of the transferor (or earlier death of the transferee) inclusive.

Example

Andrew gives Brian shares in Y Ltd, an unquoted company. By the time of Andrew’s death four years later in 2001 the company’s shares are listed on a recognised stock exchange.  Brian still owns the shares. Though the condition in IHTA84/S227 (1C)(a) is satisfied, the additional condition for gifts of unquoted shares is not, so instalments are not available.

Note that, unlike Business Relief (IHTM25131), there is no retrospective provision for the tax charge (or further charge) on a death on or after 10 March 1992 in respect of a lifetime transfer before that date.