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HMRC internal manual

Inheritance Tax Manual

Changes after the issue of the clearance certificate: sales of unquoted shares

If 100% business relief (IHTM25131) is not available, the prices realised on the sale of a holding of unquoted shares may be a material factor in considering the value of the holding for Inheritance Tax purposes. If, therefore, you become aware of a sale that took place before the certificate was issued, you should ask Shares and Assets Valuation (SAV) whether, in the circumstances, it could be strongly argued that the sale was a material factor in valuing the holding at the time of the deceased’s death. The decision on the effect of the certificate, and the conduct of any correspondence, remain a matter for the investigator.