»Ê¹ÚÌåÓýapp

This restriction applies if only part of the holding is included in the deceased’s estate.  »Ê¹ÚÌåÓýapp loss on sale, restricted as necessary, is deducted from the value of the entirety of the investments. »Ê¹ÚÌåÓýapp resulting figure is then apportioned according to the values of:

• the part of the holding comprised in the estate, and
• the entirety of that holding, IHTA84/S186.

Example

Aries trust fund comprises 1,000 Black plc shares, valued immediately before death at £4,000.  Of this 250 shares with a value of £1,000 is comprised in the deceased’s estate.

Two months after the death the holding is sold for £3,000.  »Ê¹ÚÌåÓýapp overall loss on sale is £1,000 and the value of the entirety of the holding after relief becomes £3,000.

»Ê¹ÚÌåÓýapp value of that part of the holding comprised in the estate is revised to

(1,000 ÷ 4,000) x £3,000 = £750