A client is intending to invest in companies quoted on AIM to take advantage of the business property relief exemption for unquoted shares for inheritance tax purposes. However, two questions have arisen. Do shares held through a nominee qualify (the Revenue's manuals only refer to "beneficial ownership")? Do oil/mining shares represent qualifying activities or are they caught by the "land" exclusion?
Peter Bates
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Beneficial ownership will include shares held by a bare nominee
The "land " exclusion [IHTA s105(3)] refers only to "dealing in .....land or buildings... or... making or holding investments". Mining is manifestly neither of these.