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HMRC internal manual

Inheritance Tax Manual

Sales: suspension of shares

For deaths on or after 16 March 1992, relief is available if

  • qualifying investments (IHTM34131) are held at death
  • the quotation is subsequently suspended and remains suspended 12 months after the date of death
  • the appropriate person (IHTM34161) still holds the shares at the end of that period, and
  • the value at the end of that period is less than the date of death value.

If all of the above conditions apply the shares are treated as having been sold immediately before the end of the period of 12 months following the date of death for a price equal to their value at that time, IHTA84/S186B.

This rule applies to all suspensions not only those that arise because a company collapses.

Special treatment (IHTM34134) also applies to shares that were suspended at death but which subsequently had their quotation restored.