Inheritance Tax Act 1984 section 228

Shares, etc. within section 227

Section 228 identifies which shares and securities qualify for the payment of inheritance tax by instalments under section 227, setting out four categories and the conditions each must meet.

• Shares or securities that gave the deceased, trustees, or transferor control of the company immediately before the chargeable transfer always qualify for instalment payments.
• Unquoted shares or securities qualify on death if at least 20% of the tax for which the person paying is liable (in the same capacity) consists of tax attributable to those shares or other tax that may itself be paid by instalments.
• Unquoted shares or securities qualify where HMRC are satisfied that paying the tax in a single sum would cause undue hardship.
• Unquoted shares qualify where the value transferred attributable to them exceeds £20,000 and their nominal value represents at least 10% of all the company's shares (or, if they are ordinary shares, at least 10% of all the company's ordinary shares).