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HMRC internal manual

Inheritance Tax Manual

Changes in shareholdings: part of rights sold, balance taken up as shares

This situation is not straightforward and is best looked at by means of an example

Example

The deceased’s estate includes a holding of 1,000 qualifying shares valued at £2,000. The shares are bequeathed to C, the sole executor. There is a rights offer on a 1 for 1 basis at £1 per share. C sells for £210 on the Stock Exchange the right to accept 500 shares. C accepts the remaining 500 shares, at a cost of £500, making a new holding of 1,500 shares.

C subsequently sells 1,000 shares for £1,300 and later the remaining 500 shares for £650, both sales being at the same price per share.

In accordance with the general approach for calculating the losses on the sales:

  • the value on death has to be increased to reflect the cost of the new shares, £500

    and

  • the sale price of the shares sold have to be increased to reflect the sale proceeds of the rights, £210.

Under IHTA84/S183 (3) the value on death of the new holding of 1,500 shares is the original date of death value plus the cost of the new shares, i.e. £2,000 + £500 = £2,500.

The value on sale of the 1,000 shares sold is (under IHTA84/S181) £1,300 + (2/3 ( £210) = £1,440. Applying the formula (IHTM34183) in IHTA84/S183 (5) the value on death of the investments sold is

  Vs(H - S) = 1,440(2,500 - 0) = £1,722
       
  Vs + Vr 1,440 + 650  

There is a loss on sale of £1,772 - £1,440 = £282

The value on sale of the 500 shares subsequently sold is (under IHTA84/S181) £650 + (1/3 x £210) = £720. Again applying the formula in IHTA84/S183 (5), the value on death of the investments sold is

    720 (2,500 - 1,722) = £778
       
    720  

There is a loss on sale of £778 - £720 = £58

If the application of the formula in this sort of case is challenged by the taxpayer, please refer to TechnicalG (IHTM01081).