IHTM24101 | Ownership: The meaning of ownership
From HM Revenue & Customs · Inheritance Tax Manual
Ownership is considered to mean
in the case of property subject to relevant property trusts, () legal ownership by the trustees
in all other cases, beneficial entitlement () which includes entitlement to settled property in which the deceased/transferor had a beneficial interest in possession. ()
In view of , where an unadministered residuary estate includes agricultural property, a residuary beneficiary is treated as owning the agricultural property, or an appropriate share of it. ()