Commentary

I8.317 Unquoted holdings of 50%

IHT, trusts and estates

I8.317 Unquoted holdings of 50%

I8.317 Unquoted holdings of 50%

For reasons given in I8.316, valuation of holdings of this type will in many cases be unnecessary because of the higher rate of business relief.

In the absence of any special provisions in the articles of association, a 50% holding does not control the company, but it does normally prevent any one else from so doing. When there are only two shareholders, each holding 50% of the shares, the possibility of disharmony and deadlock is an important factor in the valuation1; but, if the 50% holder is faced by a number of smaller holdings, he will

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