IHTM40145 - Changes after the issue of the clearance certificate: sales of unquoted shares
If 100% business relief (IHTM25131) is not available, the prices realised on the sale of a holding of unquoted shares may be a material factor in considering the value of the holding for Inheritance Tax purposes. If, therefore, you become aware of a sale that took place before the certificate was issued, you should ask Shares and Assets Valuation (SAV) whether, in the circumstances, it could be strongly argued that the sale was a material factor in valuing the holding at the time of the deceased’s death. The decision on the effect of the certificate, and the conduct of any correspondence, remain a matter for the investigator.
Note that from 6 April 2026, unquoted shares in companies listed on a market that does not meet the definition of ‘listed’ for HMRC purposes (such as AIM) will qualify for relief at 50% (not 100%) if the qualifying criteria are satisfied (see IHTM25570). For other unquoted shares, remember that 100% relief is only available up to the amount of the available relief allowance (IHTM25500).