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HMRC internal manual

Inheritance Tax Manual

Changes in shareholdings: rights not taken up or sold

If the ‘appropriate person’ (IHTM34161) does nottake up the rights issue then the company may sell the rights on behalf of the appropriateperson. If it does it may pay the proceeds to the appropriate person in respect of lapsedrights. Where this happens the sums received are a capital payment (IHTM34177) and should be added to any sale price, IHTA84/S181.

The terms of the rights issue will determine whether any sale takes place or capitalpayments are made.