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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Qualifying property (PETs): control holdings

The conditions are the same as with transfers on death (IHTM30217). However, you should note:

  • for lifetime transfers, this applies to shares or securities of a company which gave the transferor control of the company immediately before the transfer
  • instalments are available for any transfer out of a control holding.