IHTM30214 | Transfers on death: businesses and interests in businesses

From 6 April 2026, if property qualifies for (BR) (IHTM25131) it will also qualify for instalments and these will be interest free (IHTM30363) see IHTA/S227(2)(aa) and IHTA/S234(1)(a)).

A business or an interest in a business is also qualifying property for instalments - IHTA84/S227 (2)(c) even if it does not qualify for BR.

The basic definitions are similar to those for BR:

• the value is the net assets value (compare IHTA84/S110)

• business includes profession or vocation but does not include a business carried on otherwise than for gain (compare IHTA84/S103 (3)).

Accordingly the instructions on the meaning of business (IHTM25051) elsewhere in the Manual apply.

Interest relief

From 6 April 2026, any property which qualifies for BR or Agricultural Relief (AR) is also qualifying property for interest free (IHTM30363) instalments.

Before that date, property which qualified for BR under IHTA84/S105 (1)(a) was also qualifying property for interest free (IHTM30363) instalments.

(If the BR is at 100%, this is academic. 100% relief might be available because the death was between 10 March 1992 and 6 April 2026 or, after that date, if the value is entirely covered by the 100% relief allowance see IHTM25500.)

In addition, whenever the death, interest free instalments are available under IHTA84/S227 (2)(c) and IHTA84/S234 (1)(a) for

• any excepted assets (IHTM25351) disallowed for BR under IHTA84/S112

• businesses excluded from BR because the ownership condition (IHTM25301) is not satisfied or they are investment businesses (IHTM25261)

• agricultural property (IHTM24030) which is an asset of a qualifying business but is excluded from BR by IHTA84/S114 (1).

These instructions do not apply to holdings of quoted or unquoted shares (IHTM30215) in limited companies.