SolvedSVM112110 | IHT Agricultural Property Relief: Replacement Provisions (Shares or Securities)
From HM Revenue & Customs · Shares and Assets Valuation Manual
Where the shares or securities transferred replaced other eligible property, the condition in section 123(1)(b) IHTA 1984 is treated as satisfied if the shares or securities, the eligible property they replaced and any eligible property directly or indirectly replaced by the other eligible property were owned by the transferor for periods which together comprised
for the two years test, at least two years out of the five years ending with the transfer date.
for the seven years test, at least seven years out of the ten years ending with the transfer date.
In this context, eligible property means
agricultural property owned personally by the transferor (including any such property which may have been transferred to the company in exchange for the shares or securities), or
a control holding in another farming company.
Sections 123(4), 118(3) and 118(4) IHTA 1984
Where the ownership test is satisfied under the replacement provisions, relief is restricted to what it would have been had the replacement, or any earlier replacement to be taken into account, not been made. These restrictions apply to all replacements except that changes resulting from the formation, alteration or dissolution of a partnership are disregarded.
Additional Guidance: SVM150000