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HMRC internal manual

Inheritance Tax Manual

Qualifying investments: reversionary interests

You should not normally treat shares comprised in a reversionary interest (IHTM16231) as part of the estate for the purposes of this relief.  This is because a reversionary interest is normally excluded property (IHTM04251) under IHTA84/S48 and does not form part of the deceased’s estate under IHTA84/S5 (1).  The qualifying investments (IHTM34131) must be in the deceased’s estate in order to be considered for relief, IHTA84/S178 (2).      

However where a reversionary interest is not excluded property (IHTM04281) the shares comprised in that reversionary interest do form part of the estate for the purposes of loss on sale of shares relief.