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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Attribution of values to specific investments: summary

Loss on sale of shares relief is given by reducing the overall value of the sold investments by an amount equal to the ‘loss on sale’ (IHTM34171). This is all you will need to with most claims that you consider. But IHTA84/S187 provides a means of determining the revised value for each individual asset that is included in the claim. This is something that is mainly required for CGT purposes because this value is also substituted for the date of death value in calculating the CGT liability. You will generally only need to provide values for specific investments if

  • you are asked by the tax office to let them have the revised date of death values for the investments included in a claim, or
  • you need to provide this information to the tax office when a claim for relief is received more than two years after the date of death (IHTM34074). You may also have to determine the revised value for a specific investment when there is also a claim for Double Taxation Relief (


In most cases this is a straightforward exercise – the revised value will be the sale value. But the sale value will need to be recalculated if one of the following applies

  • ‘call’ (IHTM34242) is paid
  • there is a change in the capitalisation of a company (IHTM34243), or
  • there are purchases of qualifying investments (IHTM34244).