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HMRC internal manual

Inheritance Tax Manual

Calculating the loss: value on death

The general rule is that the value on death of any qualifying investment (IHTM34131) is

  • the value on the normal open market basis (i.e. excluding this relief), IHTA84/S179 (1) (a), plus
  • the amount of any call (IHTM34175) paid since the death, IHTA84/S182.

The main exception to the general rule is where the investment forms part of a new holding (IHTM34181) within IHTA84/S183 (1). 

Ex-dividend valuations

Dividends that were included in the death estate because of an ex-dividend valuation are excluded in the date of death value of the holding for the purposes of this relief.  Only the actual capital value of the holding at the date of death should be used.