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HMRC internal manual

Inheritance Tax Manual

Changes in shareholdings: date of death value for the whole of a new holding

The date of death value of the whole of a new holding which results from a transaction under IHTA84/S183 is

  • the value on death of the original holding plus
  • the amount of any consideration, other than of the nature described in IHTA84/S183 (4), given in connection with the transaction.

The value on death of the particular investments sold is determined by the formula (IHTM34183) in IHTA84/S183 (5).

The consideration included in IHTA84/S183 (4) is

  • ‘Any surrender, cancellation or other alteration of any of the investments comprised in the original holding or the rights attached thereto’
  • ‘any consideration consisting of any application, in paying up the new holding or any part of it, of assets in the company concerned or of any dividend or other distribution declared out of those assets but not made.’