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HMRC internal manual

Shares and Assets Valuation Manual

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HM Revenue & Customs
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IHT Agricultural Property Relief: Shares / Securities subject to a binding contract for sale

Relief is not available when the shares or securities concerned are subject to a binding contract for sale at the time of the transfer, except where the sale is made for the purpose of reconstruction and amalgamation.

s.124(2)

There is a similar provision for business relief (s.113) and, therefore, the instructions at SVM111120 should also be treated as applying in this context.

s.124(1)

Where agricultural property owned by a company was itself subject to a binding contract for sale at the time of the transfer of value, you should refer the case to the Appeals Team.
 

  Additional Guidance: SVM150000