SolvedIHTM34181 | Changes in shareholdings: changes in the capitalisation of a company
From HM Revenue & Customs · Inheritance Tax Manual
Special rules apply when there is a change to the shareholdings that are being dealt with by the appropriate person (IHTM34161) as a result of changes in the capitalisation of a company.
IHTA84/S183 applies when
within a year of death
in relation to any of the qualifying investments (IHTM34131)
there is a transaction to which section 127 of the Taxation of Chargeable Gains Act 1992 applies.
Broadly speaking this means a transaction involving
a reorganisation of capital
a conversion of securities
an issue of shares or debentures (in certain circumstances)
changes to a unit trust scheme that corresponds to any of the above transactions.
A transaction within IHTA84/S183 is not treated as a sale. For the purposes of the relief the new holding which results from the transaction is treated as being the same as the original holding.