IHTM30212 | Transfers on death: categories of qualifying property

From HM Revenue & Customs · Inheritance Tax Manual

The categories are:

  • land ()

  • from 6 April 2026, property which qualifies for business relief (BR) () (see below)

  • businesses ()

  • shares: control holdings ()

  • unquoted shares: undue hardship ()

  • unquoted shares: 20% tax test ()

  • unquoted shares: £20,000 value and 10% nominal value test ().

The following pages provide detailed instructions on their treatment.

Property which qualifies for BR

From 6 April 2026:

  • there is a 100% relief allowance () for the combined value of qualifying business and agricultural property, and the value over that amount gets relief at 50%

  • additionally, shares in companies listed on a market that does not meet the definition of ‘listed’ for HMRC purposes (such as AIM), can now only qualify for 50% relief if the conditions are met ().

From the same date, any property which qualifies for BR will also qualify for instalments. Those instalments will be interest free () - see IHTA/S227(2)(aa) and IHTA/S234(1)(a)).

If property qualifies for BR at 100%, either because the transfer was before 6 April 2026 or, after that, because it is covered by the 100% relief allowance, then instalments will not be relevant.