Client has died. She owned portfolio of EIS shares on which she was able to claim income tax and CGT reliefs. She has owned all the shareholdings for more than 2 years but some of the companies have only been trading for just over a year. Under s 105(1)(bb) as the shares are unquoted they qualify for the relief once held for 2 years (s106), however S105(3) prevents a claim for (broadly) non trading companies. What I cannot find the answer to is how these provisions interact. If the shares had been held for 2 years, and were in a trading company at the date of death is BPR due? Or does the comapny have to have been trading for 2 years at date of death? Strangely I cannot seem to find a definitive answer on this.