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HMRC internal manual

Inheritance Tax Manual

Qualifying investments: reversionary interests

You should not treat shares comprised in a reversionary interest (IHTM16231) as part of the estate for the purposes of this relief.This is because the reversionary interest is excluded property (IHTM04000)under IHTA84/S48 and does not form part of the deceased’s estate under IHTA84/S5 (1).The qualifying investments (IHTM34131) must be in thedeceased’s estate in order to be considered for relief, IHTA84/S178 (2).