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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Qualifying investments: shares held by a partnership

Usually, the deceased partner is not beneficially entitled to the specific assets held by a partnership. This means that investments held by a partnership will not normally be considered as being within the estate and can be ignored when considering a claim for loss on sale of shares relief.

But there may be circumstances where investments used by a partnership are in fact the property of an individual partner. This may be apparent from the partnership agreement or when we are informed of this by the taxpayers. If it is intended to claim that the deceased partner was the owner of specific assets of the partnership, you should first refer the case to Technical (IHTM01081).