IHTM30218 | Transfers on death: unquoted shares - undue hardship

From 6 April 2026, unquoted shares which attract Business Relief (BR) will also be eligible for interest free instalments (IHTM30363) see IHTA/S227(2)(aa) and IHTA/S234(1)(a)). See also IHTM25570 and IHTM25580.

If BR is not available, unquoted shares or securities that do not represent a control holding (IHTM30217) of a company qualify for instalments if the Board are satisfied that the tax attributable to their value cannot be paid in one sum without undue hardship.

You should refer any claim for instalments under IHTA84/S228 (1)(c) immediately to your manager. Further instructions on the operation of IHTA84/S228 (1)(c) are given in connection with potentially exempt transfers (PETs) (IHTM30254).