»Ê¹ÚÌåÓýapp

»Ê¹ÚÌåÓýapp meaning of the term ‘unquotedâ€� for instalment purposes has not been constant and has diverged from the general definition provided by IHTA84/S272 as introduced by the FA 1987 with effect from 17 March 1987.

With effect from 1 April 1996 the word ‘quoted on a recognised stock exchangeâ€� in IHTA84/S227 (1AA) and in IHTA84/S272 was replaced by the word ‘listedâ€�. »Ê¹ÚÌåÓýapp term ‘recognised stock exchangeâ€� was defined by TA88/S841, but with effect from 28 November 2001 HMRC adopted a revised interpretation. For further information see IHTM18131.

With one exception the point will rarely arise since, with effect from 1 April 1996, all unquoted shares will qualify for 100% Business Relief unless they fall within IHTA84/S105 (3). If they fall within that section, or are as described in IHTA84/S105 (4) (see IHTA84/S234 (2) and IHTA84/S234 (3)(a)), they will only qualify for interest free (IHTM30363) instalments to the extent that the value is treated as reduced by Agricultural Relief (IHTM24000).

»Ê¹ÚÌåÓýapp exception is where the unquoted shares would have qualified for 100% Business Relief but for the provisions of IHTA84/S106, i.e. they were not owned by the transferor throughout the two years immediately preceding the date of transfer. In this case the shares will qualify for interest free instalments.