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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Employee benefit trusts: conditions for relief: Share Price Schemes (other than approved under TA88/SCH9)

In some employee benefit trusts the price at which shares are to be purchased by the trustees from the company or other shareholders is fixed by reference to a formula or to a ‘fair value’. You should consider these transactions carefully, to ensure that the transaction is not used to transfer value that is more than the true open market value of the shares to the shareholders. Shares and Assets Valuation will be able to help you to work out what might be considered the open market value of the shares.