IHTM34220 - Restrictions on relief: part holdings comprised in the deceased鈥檚 estate

This restriction applies if only part of the holding is included in the deceased鈥檚 estate.聽 The loss on sale, restricted as necessary, is deducted from the value of the entirety of the investments. The resulting figure is then apportioned according to the values of:

  • the part of the holding comprised in the estate, and
  • the entirety of that holding, IHTA84/S186.

Example

Aries trust fund comprises 1,000 Black plc shares, valued immediately before death at 拢4,000.聽 Of this 250 shares with a value of 拢1,000 is comprised in the deceased鈥檚 estate.

Two months after the death the holding is sold for 拢3,000.聽 The overall loss on sale is 拢1,000 and the value of the entirety of the holding after relief becomes 拢3,000.

The value of that part of the holding comprised in the estate is revised to

(1,000 梅 4,000) x 拢3,000 = 拢750