IHTM25172 - Unquoted securities - control holding: When is the transferor required to have control?

Under IHTA84/S105 (1)(b) the transferor is required to have had control only immediately before the transfer and not during any earlier period. However, the ownership test ( IHTM25301) still applies so that any securities acquired by the transferor within two years of the transfer will not qualify for relief unless by virtue of the provisions for replacement property ( IHTM25311), successions ( IHTM25321) or successive transfers ( IHTM25331).