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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),


  • 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). This occurs where the original holding changes as a result of, for example, a reorganisation of share capital, a conversion of securities, or an issue of shares or debentures in certain circumstances.


Ex-dividends that were included in the death estate are not included in the date of death value of the holding for the purposes of this relief. Only the actual value of the holding at the date of death should be used.

USM shares

Special rules (IHTM34133) apply for calculating the date of death value of shares listed on the Unlisted Securities Market (USM).