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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Changes in shareholdings: date of death value for investments sold

The following formula, IHTA84/S183 (5), is used to calculate the value on death of anyinvestments comprised in the new holding that are sold by the ‘appropriatepersons’ (IHTM34161).

  Vs (H – S)  
  (Vs + Vr)  


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 newholding but have been sold on a previous occasion or occasions.

The ‘sale value’ (IHTM34176) is that established bythe general rule.

‘Market value’ means the value the shares would have (apart from this relief) ifthey were comprised in the value of an estate at that time. The ¼ up value at the date ofsale is used.