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HMRC internal manual

Inheritance Tax Manual

Qualifying investments: shares temporarily suspended at the date of death

Where the quotation of shares is suspended at the date of death but is subsequently restored the shares are treated as qualifying investments if they are sold within 12 months of the death, IHTA84/S178 (2).

The date of death value will be the grey market value. Refer to Shares and Assets Valuation to request a valuation if needed.  The sale value is calculated in the normal way.

Special treatment also applies to shares that are qualifying investments at the date of death but which are subsequently suspended or cancelled.

If the shares are cancelled within 12-months of the date of death, and they are not replaced by other shares, IHTA84/s186A says that the shares are treated as being sold by the appropriate person for a nominal consideration (£1).  

If the shares are still suspended at the 12-month anniversary of the death then the grey market value should be entered in column B of IHT 35.  

If the shares were suspended at death and they continue to be suspended throughout the following 12 months no relief is due.  This is because the investment is not quoted at any relevant time.