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HMRC internal manual

Inheritance Tax Manual

Attribution of values to specific investments: payment of ‘call’

The revised value of any specific investment is the sale value less the amount of any call paid, IHTA84/S187 (4).  You should note that this is different from the way you calculate the loss for the purposes of the relief where, as in the example at (IHTM34175), you add the call to the date of death value.

If a call is paid and there is a subsequent transaction (IHTM34243) to which IHTA84/S183 applies we take the view, based on analogy with IHTA84/S187 (5), that a proportion of the call should be deducted.  The proportion will be based on the respective values on death of the investments sold or exchanged and of new holding.

If this view is contested you should refer the matter to Technical (IHTM01081).