IHTM25191 | Other holdings of unquoted shares: Rate of relief

The rate of relief for IHTA84/S105(1)(bb) property is

• 100% which is unlimited for transfers effected on or after 6 April 1996 until 5 April 2026, or where the charge to tax arises on an earlier transfer by reason of an event occurring on or after that date.

From 6 April 2026,

• the 100% rate only applies up to the available amount of the transferor’s 100% allowance, and any value of a chargeable transfer exceeding the available allowance will only be relieved at 50% (IHTM25500).If the shares are traded on a UK recognised stock exchange (and the market is not ‘listed’ for HMRC purposes) or are traded on a stock exchange outside the United Kingdom which is not a recognised stock exchange, the rate is 50% (IHTM25570). These shares now fall under the new categories of IHTA84/S105(1)(aa) and (ac) respectively.

These revised rates will also apply to transfers made on or after 30 October 2024 if the transferor dies on or after 6 April 2026 and within 7 years of the transfer, except for shares traded on a stock exchange outside the United Kingdom which is not a recognised stock exchange.