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HMRC internal manual

Inheritance Tax Manual

Sales: date of sale

The date of sale is either

  • the date of the contract note, or
  • the date on which any option to sell or purchase was granted, (IHTA/S189)

In the case of appropriations (IHTM34153) the date of sale is the date of appropriation (Re Charteris, Charteris v Biddulph [1917] 2 Ch 379).  Formal evidence, such as an instrument of appropriation, will normally exist to demonstrate that steps were taken to vest assets in the legatee.