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HMRC internal manual

Inheritance Tax Manual

Restrictions on relief for purchases: purchases of ‘qualifying investments’

For the purposes of this restriction the origin of the purchase money is immaterial.  It does not have to come from the proceeds of the investments sold.

The following do not count as purchases of qualifying investments for the purposes of this restriction

  • a payment of call (IHTM34175)
  • a subscription for the allotment of shares or the taking up of a rights issue (but if any part of the holding acquired in this way has been sold, you will need to apply the formula (IHTM34183) in IHTA84/S183 (5) to establish the date of death value for the part of a new holding)