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HMRC internal manual

Inheritance Tax Manual

Changes in shareholdings: date of death value for investments sold

The following formula is used to calculate the value on death of any investments comprised in the new holding that are sold by the appropriate persons (IHTM34161), IHTA84/S183 (5).

Vs (H-S) ÷ (Vs + Vr)

Where

Vs  =    the sale value of the investments

Vr   =   the market value at the time of the sale of any investments in the new holding    

            that have not been sold

H    =   is the value on death of the new holding

S    =    is the value on death of any investments that were originally comprised in the new holding but have been sold on a previous occasion or occasions. 

The sale value (IHTM34176) is that established by the general rule.

Market value means the value the shares would have (apart from this relief) if they were comprised in the value of an estate at that time.  The ¼ up value at the date of sale is used. (IHTM18093)