Inheritance Tax Act 1984 section 186

Value of part of a fund

Section 186 deals with how the sale relief provisions apply when only part of a holding of qualifying investments is included in the deceased's estate.

• Where only part of a holding of qualifying investments forms part of the deceased's estate, the relief chapter applies as if the entire holding were included in the estate.
• If qualifying investments from that holding are sold within 12 months of the death, a claim can be made for relief based on a taxable fraction of the sale values.
• The taxable fraction is calculated by dividing the value of the part of the holding in the estate by the value of the entire holding, both valued without the relief.
• The relief is then limited to that fraction of the value of the investments covered by the claim, ensuring only the estate's proportionate share benefits from the relief.