IHTM42660 | Discretionary trusts: unquoted shares
From HM Revenue & Customs · Inheritance Tax Manual
It is important that you refer to Shares and Assets Valuation (SAV) in all cases where there may be tax at stake.
Refer all 100% or 50% agricultural relief (AR) or business relief (BR) claims on unquoted shares. ()
Take particular care with disposals of shares which no longer qualify for relief.
If the shares qualified for 100% relief at set-up then there will have been no chargeable relevant property on which to levy a tax charge and nil tax to pay on that occasion.
Similarly for shares qualifying for relief at the anniversary of the trust if the charge is on or after 6 April 2026.
So, it may at first appear that there is no rate of tax on the subsequent disposal.
However, the rate for exit charges, whether before or between 10-year anniversaries is now calculated on historic values without the benefit of any reliefs and on that basis there may be a rate. ()
This is particularly relevant if shares in a company are floated on the stock exchange and do not then qualify for BR.
Historic values
SAV will also provide advise if you need to obtain a historic value purely for calculating rate.
Delay
The valuation may take some time, so it may be worthwhile reminding the taxpayer to place a suitable amount on deposit.