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HMRC internal manual

Inheritance Tax Manual

Qualifying investments: non-qualifying investments

Unquoted shares and shares traded on the Alternative Investment Market (AIM) do not qualify for relief.  This includes Business Expansion Scheme (BES) shares.

To qualify for relief an investment must be quoted at the date of death, IHTA84/S178 (1).  This means that no relief is due where, for example, the company was not floated until after the death.  But if an investment was only suspended at the date of death relief may be due (IHTM34134).

If at any stage the taxpayer or agent argues that an AIM investment is quoted you should refer the matter to Technical (IHTM01081).

Unit linked investment bonds will not normally be a qualifying investment for the purposes of IHTA/178 (1) because the deceased generally does not own the underlying units. In the most common situation these are insurance based bonds where the value is linked to the units but the deceased does not own the underlying units.

If the parties dispute that the investments are not qualifying investments please obtain full details and documentation showing exactly what the asset is and then refer to Technical.