Commentary

I8.316 Unquoted holdings over 50% but below 75%

IHT, trusts and estates

I8.316 Unquoted holdings over 50% but below 75%

I8.316 Unquoted holdings over 50% but below 75%

The introduction of the higher rate of business relief of 100%1, which since 5 April 1996 has applied to all unquoted shares qualifying for relief2, means that in many cases it will not be necessary to value unquoted holdings with 50% or more of the votes. There may still be some holdings which have to be valued, for example because the transferor has not owned them for the requisite two years before a transfer occurs3, or the company is a property or investment holding company4, or owns excepted assets5.

The purchaser acquiring over

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