IHTM25191 - Other holdings of unquoted shares: Rate of relief

The rate of relief for IHTA84/S105 (1)(b) property is

• 100% for transfers effected on or after 6 April 1996, or where the charge to tax arises on an earlier transfer by reason of an event occurring on or after that date.

If there was a lifetime transfer (IHTM140001) before 5 April 1996 which was chargeable when made, the 100% rate applies only for the purpose of calculating the second tax charge on the transferor's death. The value for cumulation is based on the 50% rate applying at the date of the transfer. If such a transfer were a “failed” PET the rate of relief would be 100%.