Close Companies and IHT UK 2026: s94 IHTA Transfers Attributed to Participators, s98 Share Capital Alterations, BPR Interaction, and the FA 2026 Cap
When a close company makes a transfer of value, s94 IHTA 1984 attributes it to the shareholders pro-rata — triggering IHT consequences for individuals. Share capital restructuring can trigger s98. BPR applies where the company trades — but the FA 2026 £1m cap limits 100% relief.
Close Company Transfers = Personal IHT Transfers for Shareholders — Know the Rules Before Restructuring
s94 IHTA 1984: close company transfer of value → attributed to participators in proportion to their interests → each participator treated as making a PET or CLT of their share. s98 IHTA: share capital alteration that diminishes one participator's value = transfer of value by that participator. BPR available on attributed transfers for qualifying trading companies (100% — but capped at £1m from FA 2026). Interest-free loans, free asset use, excessive pay to family members = common s94 triggers. IHT100 reporting for CLTs; estate IHT400 for PETs on death. Annual arm's-length review of close company transactions is essential for owner-managers.
| Aspect | Rule / Principle | Example / Scenario | Planning Guidance |
|---|---|---|---|
| s94 IHTA — close company transfers attributed to participators | s94 IHTA 1984 — THE CORE PROVISION: 'Where a close company makes a transfer of value, tax shall be charged as if each individual who is a participator in the company had made a transfer of value of an amount equal to the appropriate portion of the value transferred by the company.' THE APPROPRIATE PORTION: the value transferred by the company is apportioned among participators in proportion to their interests in the company. The 'interest' is defined broadly: includes shares, rights to participate in distributions, loan creditor rights, rights under options, and other forms of economic participation. WHAT IS A TRANSFER OF VALUE BY THE COMPANY? The general s3 IHTA 1984 definition applies: any disposition that results in a decrease in the value of the close company's estate. Examples: (a) the company makes a loan to a participator's family member at below-market (or zero) interest; (b) the company provides free use of an asset (company car; property) to a participator's family; (c) the company pays excessive remuneration to a connected person (beyond arm's length value); (d) the company makes a gift to a charity in a manner that reduces the company's value to shareholders; (e) the company waives a debt owed to it by a participator. NOT INCLUDED: normal commercial transactions at arm's length; dividends properly declared (treated as consideration for SDLT purposes and income tax purposes — not IHT transfers); remuneration at market rates to director-employees. ATTRIBUTION TO PARTICIPATORS: the value is apportioned pro-rata. If a participator holds 30% of the company and the company makes a £100k gift: the participator's attributed transfer = 30% × £100k = £30k. The participator is treated as having made a £30k PET or CLT (depending on whether the attributed transfer is to an individual or a trust). | s94 WORKED EXAMPLE: Highfield Ltd is a close company owned equally by brothers Alan (50%) and Brian (50%). The company makes an interest-free loan of £200k to Alan's daughter Chloe. This is a TRANSFER OF VALUE by Highfield Ltd (the loan has value below market rate — the interest forgone is a benefit to Chloe; the company's value is diminished by the forgone interest and risk). s94 ATTRIBUTION: Alan's appropriate portion = 50% × £200k (or the forgone interest component) = £100k. Brian's appropriate portion = 50% = £100k. IHT CONSEQUENCE FOR ALAN: the attributed transfer of £100k is treated as a transfer by Alan to Chloe (his daughter). This is a PET (a gift from Alan to an individual — Chloe). 7yr PET clock starts. If Alan dies within 7yr: the attributed PET is chargeable. IHT CONSEQUENCE FOR BRIAN: the attributed transfer of £100k is treated as a transfer by Brian to someone (but Brian has no connection to Chloe — the attribution is mechanical, not conditional on who benefited). Brian has notionally made a £100k PET to Chloe. This can be inequitable where one participator benefits but another is attributed a transfer. THE RELIEF: s94(5) IHTA — if the attributed transfer is covered by BPR (the company qualifies as a trading company for BPR), the participator can claim BPR on their attributed share. But post-FA 2026: the £1m cap on 100% BPR applies to the participator's total BPR position. | WHEN DOES s94 TYPICALLY ARISE IN PRACTICE? (1) BELOW-MARKET LOANS TO CONNECTED PERSONS: interest-free or below-market-rate loans from a close company to shareholders' family members. The forgone interest = transfer of value by the company. (2) USE OF COMPANY ASSETS: the company lets a family member use a company asset (car, holiday property) at below-market value or free. (3) EXCESSIVE EMOLUMENTS: the company pays a director's family member a salary that exceeds the market rate for their services. HMRC will scrutinise remuneration that appears commercially excessive. (4) DEBT WAIVERS: the company waives a debt owed by a participator or connected person. The debt waiver = transfer of value. PLANNING TO AVOID s94: (a) ensure all transactions between the company and connected persons are at ARM'S LENGTH (market rates); (b) document the commercial justification for all payments; (c) charge interest on shareholder loans at the HMRC official rate or above; (d) charge market rent for any property or asset use; (e) set salaries at genuinely commercial rates (supported by independent remuneration benchmarks). REPORTING: the participating individual must self-assess any attributed transfer as a PET or CLT on their self-assessment return. The company's transfer of value may also need reporting by the company in its corporation tax return. HMRC has powers to assess the attributed transfer on the individual (not just the company). |
| s98 IHTA — alterations in close company share capital | s98 IHTA 1984 — SHARE CAPITAL ALTERATIONS: 'Where the value of an individual's estate is diminished, and the value of a close company's unquoted shares is increased, by reason of an alteration in the company's share capital or in the rights attaching to unquoted shares, the individual shall be treated as having made a transfer of value of an amount equal to the amount of the diminution.' WHY s98 EXISTS: without s98, a close company could restructure its share capital to shift value from one participator to another without IHT consequences. Example: the company issues new shares to the owner's children at nominal value, diluting the value of the parent's existing shares. Without s98: the parent has simply been diluted — no IHT. With s98: the diminution in the parent's share value = a transfer of value by the parent to whoever received the increased value. WHAT TRIGGERS s98? (a) an allotment of new shares at below-market value (e.g., nominal value) to new or existing shareholders — the existing shareholders' values are diluted; (b) variation of share rights: converting one class of shares to another with more valuable rights (e.g., converting preference shares to ordinary shares with higher rights); (c) cancellation of shares: repurchasing one class of shares in a way that enriches other shareholders; (d) payment of an excessive dividend or distribution on one class that diminishes another class (can overlap with s94). THE AMOUNT OF THE TRANSFER: the amount of s98 transfer = the diminution in the individual's estate attributable to the alteration — i.e., the fall in the value of their shares. NOT APPLICABLE TO QUOTED COMPANY SHARES: s98 applies only to UNQUOTED shares in a close company. | s98 WORKED EXAMPLE — GROWTH SHARES ISSUED TO CHILDREN: Oakwood Ltd (unquoted close company) is owned 100% by Margaret (ordinary shares, value: £2m). To reduce the IHT exposure, Margaret's advisers suggest issuing 'growth shares' to Margaret's children. The growth shares participate in future capital appreciation above a 'hurdle' value (£2m). At issue, the growth shares are worth £1 (nominal). POTENTIAL s98 ISSUE: if the growth shares, when issued, give the children a right to future value that diminishes the value of Margaret's shares: s98 applies. The diminution in Margaret's estate (the reduction in the value of her ordinary shares due to the growth share dilution) = a transfer of value by Margaret. HMRC scrutinises growth share schemes: the valuation of the growth shares at issue is critical. If properly valued (shares have nil or minimal value at issue because there is no current value above the hurdle): no s98 transfer. If undervalued: s98 applies to the diminution. KEY POINT: the growth share scheme must be implemented with a robust independent valuation at the time of issue. HMRC has been increasingly challenging growth share valuations in the context of both IHT (s98) and Employment Related Securities (ITEPA 2003 Part 7 — ITEPA s431 election). s98 AND EIS/SEIS SHARES: allotments under EIS or SEIS schemes are exempt from s98 (Finance Act 2014 amendment) where the allotment is at market value for EIS/SEIS qualifying purposes. | s98 PLANNING — SAFE ALLOTMENTS: allotments of new shares will NOT trigger s98 where: (a) the new shares are issued at full market value (i.e., the existing shareholders are not diluted in economic terms); (b) the allotment is pursuant to an EIS or SEIS arrangement (FA 2014 exemption); (c) the rights attaching to the new shares are equivalent in value to the consideration paid. EMPLOYEE SHARE SCHEMES: allotments under approved employee share schemes (EMI, CSOP, SAYE) are generally structured to avoid s98 by pricing shares at market value with independent valuation. For unapproved employee share schemes (or management incentive plans): s98 risk arises if connected family members receive shares at below-market value. REORGANISATIONS AND RESTRUCTURES: if a close company undergoes a reorganisation (demerger; share-for-share exchange; capital reduction), s98 may apply if the reorganisation diminishes any participator's share value to the advantage of another. Professional tax advice is essential before any close company capital restructure. DISCLOSURE: transfers under s98 are PETs (if to individuals) or CLTs (if to trusts). They should be disclosed in the participator's self-assessment return. The 7yr PET clock runs from the date of the s98 event. PENALTY RISK: failure to disclose s98 transfers can result in HMRC penalties under FA 2007 Sch 24 (failure to notify; inaccurate return). HMRC's Shares and Assets Valuation (SAV) team scrutinises close company share valuations — particularly in IHT contexts. |
| BPR and close companies — interaction with ss94-102 attributed transfers | BPR ON ATTRIBUTED TRANSFERS (ss94-102): where a transfer is attributed to a participator under s94 or s98, the participator can claim BPR (s104 IHTA) on their attributed transfer IF: (a) the transfer relates to 'business property' (the underlying asset of the company qualifies as a business — trading activities); (b) the relevant BPR conditions are met (the company has been owned for at least 2yr; it is not primarily an investment company); (c) the BPR rate is 100% or 50% depending on the type of business property. WHAT QUALIFIES? The underlying close company must be a qualifying business for BPR: (i) 100% BPR: unquoted shares in a qualifying trading company (s105(1)(bb) IHTA) — the most common BPR category for close companies; (ii) 50% BPR: a controlling interest in an unquoted company — less common; (iii) shares in an AIM company: also 100% BPR if qualifying. WHAT DOES NOT QUALIFY? Close companies that are primarily investment holding companies (s105(3) IHTA — 'wholly or mainly' investment): no BPR. Property investment companies, share dealing companies, and similar investment vehicles: no BPR. THE FA 2026 BPR CAP: from 6 April 2026, the combined 100% BPR and APR is capped at £1m per transferor. Above £1m: 50% BPR. This significantly affects participators in valuable close companies where attributed transfers exceed £1m. PLANNING: where an attributed transfer exceeds £1m and BPR is available at 100% only up to the cap: the excess is taxed at the effective rate of 20% (40% × 50% BPR). For large attributed transfers: the FA 2026 cap can result in material IHT charges. | BPR INTERACTION EXAMPLE — FA 2026 CAP: Clearwater Ltd (close company; trading; qualifies for 100% BPR). Owned 100% by Henry (value: £5m). Clearwater makes a gift of £2m to Henry's adult daughter Emma. s94 ATTRIBUTION: the full £2m transfer is attributed to Henry (100% owner). IHT CONSEQUENCE FOR HENRY: he is treated as making a £2m transfer (PET — to Emma, an individual). BPR available: the underlying asset (Clearwater shares) qualifies for BPR. FA 2026 cap: Henry's first £1m of BPR (in the tax year): 100% BPR = no IHT. The next £1m: 50% BPR = 50% × £1m = £500k chargeable to IHT if Henry dies within 7yr. IHT: 40% × £500k = £200k. PRE-FA 2026 (before 6 April 2026): the full £2m BPR at 100% = no IHT at all. POST-FA 2026: £200k IHT on the attributed transfer above the £1m cap. MITIGATION: Henry should structure the close company's transfers carefully: avoid large single attributed transfers that exceed the £1m BPR cap; spread transfers over multiple tax years to use the annual BPR cap (£1m per year) — but note BPR does not have an annual exemption mechanism like the NRB; the £1m cap is per transferor, not per tax year. Specialist advice is essential. | ESTATE PLANNING FOR OWNER-MANAGERS OF CLOSE COMPANIES: (1) KEEP THE COMPANY TRADING: the single most important action is maintaining the company as a trading company (qualifying for 100% BPR). Investment activities should be minimised or held in a separate entity. Excess cash and investment assets within the company erode BPR (s112 IHTA — excepted assets). (2) LIFETIME GIFTS: consider gifting shares in the close company during lifetime (PETs). If the donor survives 7yr: the gift is free of IHT. BPR applies at the date of gift (if still qualifying). Post-FA 2026: gifts above the £1m BPR cap are taxable at the 50% BPR rate on the excess — lifetime gifts can still save IHT compared to a death charge on the full estate. (3) FAMILY MEMBERS IN THE BUSINESS: where family members work in and hold shares in the business, the shares in their hands may independently qualify for BPR (each person's BPR position is assessed separately). Transferring shares to family members who are active in the business gives each their own £1m BPR cap (post-FA 2026). (4) EOT ALTERNATIVE: consider an Employee Ownership Trust (EOT) for a trading company over £5m in value. EOT transfer: CGT-free (s236H TCGA); IHT-free (s28A IHTA). The EOT transfer is not subject to the £1m BPR cap (it is a separate exemption). (5) CLOSE COMPANY SHARES IN WILLS: use a will trust or specific legacies to ensure company shares pass in the most IHT-efficient manner. NRB discretionary trust for cash assets; company shares pass directly to qualifying beneficiaries who can claim BPR. |
| Reporting and compliance for close company IHT events | REPORTING OBLIGATIONS: (1) s94 ATTRIBUTED TRANSFERS — SELF-ASSESSMENT: the participator must report the attributed transfer on their self-assessment income tax return (SA100 — supplementary pages for inherited wealth/IHT events are not on the SA form; IHT reporting is separate). IHT reporting: the participator must account for the attributed PET or CLT: (a) if the attributed transfer is a CLT (to a trust): report on IHT100 within 6 months of the end of the calendar month of transfer; tax due at 20% above NRB. (b) if the attributed transfer is a PET (to an individual): report on death (if within 7yr) via the estate's IHT400 return. (2) s98 ALTERATIONS IN SHARE CAPITAL — REPORTING: the s98 transfer is a deemed PET or CLT. If a CLT: IHT100 within 6 months. If a PET: reported on death (if within 7yr). The company itself should maintain records of all capital alterations (minutes of board meetings; Companies House filings on new share allotments — Form SH01 for new ordinary shares). (3) IHT AND COMPANIES HOUSE: the allotment of new shares must be filed at Companies House within 1 month (Form SH01). The allotment creates a public record — HMRC can cross-reference Companies House filings with IHT returns. (4) IHT100 (LIFETIME TRANSFERS): use form IHT100 for CLTs (e.g., attributed transfers to trusts). The IHT100 must be filed even where BPR reduces the tax to nil (HMRC requires disclosure). (5) HMRC IHT ENQUIRIES: HMRC has a dedicated close company IHT team. If a close company transfer is suspected: HMRC can open an enquiry into the company's accounts and the participators' IHT returns. Information powers under s219A IHTA 1984 allow HMRC to require information from the company about its transactions. | COMPLIANCE FAILURE — THE RISK: a close company director-shareholder (90% owner) makes an interest-free loan of £500k from the company to his son. The son buys a house with the loan. The director does not realise this is an attributed IHT transfer under s94 IHTA. He does not report the transfer on his self-assessment or IHT100. The director dies 5yr later. HMRC ENQUIRY: on reviewing the estate: HMRC notes the company loan on the balance sheet (it is a debtor in the company accounts). HMRC asks: was this an arm's length transaction? On investigation: the loan is interest-free; the son has no commercial reason for the loan from the company. HMRC assesses: (a) s94 attributed transfer on the director of £500k (90% × £500k = £450k); (b) PET (to an individual — the son) of £450k; (c) the PET is within 7yr — chargeable; (d) interest on the late-paid tax from the PET date. PENALTIES: failure to notify (FA 2007 Sch 24): 30-100% of the unpaid tax (depending on whether the failure is deliberate or non-deliberate). In this case: the director never knew the rules (non-deliberate) — but HMRC still charges interest and a penalty of 15-30% of the tax. THE LESSON: proper IHT advice for close company transactions is essential. All loans, asset uses, and payments to connected persons must be reviewed for s94 implications. | PRACTICAL STEPS FOR CLOSE COMPANY OWNER-MANAGERS: (1) ANNUAL REVIEW: review all close company transactions with connected persons annually (before the company year-end). Identify any potential s94 transfers (below-market loans, free asset use, excessive emoluments). Regularise at arm's length before year-end where possible. (2) LOAN ACCOUNTS: charge HMRC official rate interest on all loans from the company to shareholders or connected persons. This eliminates the s94 transfer of value from the forgone interest element. Keep proper records of interest charges and payments. (3) PROPERTY AND ASSET USE: where the company owns property or assets used by shareholders or their families: charge market rent (documented by an independent rental assessment; paid by direct bank transfer). (4) EMPLOYMENT: where family members are employed by the company: set salaries at independently benchmarked market rates. Remuneration above market rate is a potential s94 transfer. Have HR records (job descriptions; market rate benchmarks) available. (5) SHARE ALLOTMENTS: before allotting new shares to family members or employees: obtain an independent valuation from HMRC Shares and Assets Valuation (SAV) or a specialist valuer. Ensure the allotment price reflects full market value (avoiding s98 transfers). (6) SPECIALIST ADVICE: close company IHT is a complex area. Owner-managers should take annual IHT advice from a specialist — not just at death. The interaction between BPR, the FA 2026 cap, s94/s98, and the company's commercial structure requires ongoing monitoring. |
Close companies and IHT UK 2026. s94 IHTA 1984: 'Where a close company makes a transfer of value, tax shall be charged as if each individual who is a participator in the company had made a transfer of value of an amount equal to the appropriate portion of the value transferred by the company.' 'Appropriate portion': the apportionment is made by reference to the individuals' interests immediately after the transfer. 'Close company' as defined by s439 Corporation Tax Act 2010: a company that is under the control of five or fewer participators, or of participators who are directors. 'Participator': a person who holds shares or has a right to acquire shares; a loan creditor; a person entitled to benefits from the company under a settlement. s94(4) IHTA: the tax charged is treated as charged on the company (to the extent of the company's assets) and on the individuals (for the remainder). s94(5) IHTA: BPR (ss104-114 IHTA) applies to the attributed transfers — the participator can claim BPR on their attributed share if the underlying business property qualifies. s98 IHTA 1984: 'Where the value of an individual's estate is diminished by reason of an alteration in the unquoted share capital of a close company, or in the rights attaching to such shares, and the value of any property comprised in the estate of another individual is increased by the alteration, the alteration shall be treated as a transfer of value by the first individual.' s99 IHTA: in computing the value transferred by a company under s94, the company's liabilities may be deducted (net transfer value). s100 IHTA: attribution of transferred value to participators — set out the apportionment rules. s102 IHTA: 'Close company participators — transactions in securities'. HMRC guidance: IHTM04081 (close companies — transfers of value); IHTM04090 (s98 — alterations in share capital). BPR cap (Finance Act 2026): the combined APR and BPR of 100% is capped at £1m per transferor for transfers on or after 6 April 2026. The cap applies to the total 100% BPR relief across all qualifying transfers in the year (not per transfer). Above £1m: 50% BPR. This significantly affects participators in close companies where attributed transfers exceed £1m. HMRC Shares and Assets Valuation (SAV): the HMRC team responsible for valuing unquoted shares for IHT and CGT purposes. SAV scrutinises: (a) close company share valuations in IHT context (s94 and s98); (b) growth share valuations; (c) employee share scheme valuations; (d) valuation of shares in estate (IHT400). An SAV post-transaction valuation can be obtained to agree a share value with HMRC in advance (for certainty). Companies House filings: allotments of new shares must be filed at Companies House within one month (Form SH01 — Return of Allotments). This creates a public record that HMRC can cross-reference against IHT returns to identify potential s98 transfers. Employee Ownership Trust (EOT) as alternative: Finance Act 2023 introduced s28A IHTA — transfers of shares to a qualifying EOT are IHT-exempt (not just BPR-relieved). An EOT transfer is not subject to the FA 2026 £1m BPR cap. Combined with s236H TCGA (CGT-free disposal to EOT): the EOT is the most tax-efficient route for a qualifying trading company above the BPR cap. See /blog/iht-employee-ownership-trust-uk for a detailed comparison. IHT100 form (lifetime transfers): used for CLTs arising from close company attributed transfers. Filed by the participator (not the company) within 6 months of the end of the month in which the transfer occurs. For CLTs: tax at 20% on the excess above the available NRB is due with the IHT100 filing. IHT100 must be filed even if the tax is nil due to BPR. Finance Act 2007 Schedule 24 (penalties for inaccurate returns): applies where a participator fails to report an attributed transfer or files an inaccurate IHT return. Non-deliberate failures: 0-30% of the unpaid tax. Deliberate: 20-70%. Deliberate and concealed: 30-100%. With HMRC unprompted disclosure: penalties are reduced significantly.
Frequently Asked Questions
What does s94 IHTA mean for close company shareholders?
Section 94 IHTA 1984 provides that where a close company makes a transfer of value (any disposition that reduces the company's net value), the value transferred is attributed to the shareholders (participators) in proportion to their interests in the company. Each participator is treated as having made a transfer of value of their proportionate share. If the participator's share is 50%: they are treated as having made a PET or CLT equal to 50% of the company's transfer. This can trigger IHT consequences for individual shareholders, even if the company (not them personally) made the gift. Common triggers: interest-free loans to shareholders' family members; free use of company assets by connected persons; excessive remuneration to family members. Business Property Relief (BPR) can apply to attributed transfers where the underlying company qualifies as a trading company — but the FA 2026 £1m BPR cap limits 100% BPR.
Does issuing new shares in a close company trigger IHT under s98 IHTA?
It can — section 98 IHTA 1984 provides that where the unquoted share capital of a close company is altered and the alteration reduces the value of one participator's estate while increasing the value of another's, the first participator is treated as having made a transfer of value equal to the diminution. New share allotments at below-market value dilute existing shareholders and trigger s98. Example: a parent owns 100% of a company worth £1m and issues growth shares to children at nominal value (£1 each) — if this reduces the parent's share value by £200k: s98 treats the parent as having made a £200k PET. Finance Act 2014 introduced an exemption for EIS/SEIS share allotments at market value. Robust independent valuations at the time of any share restructuring are essential to avoid unexpected s98 transfers.
Can Business Property Relief apply to a transfer attributed under s94 IHTA?
Yes — where a transfer is attributed to a participator under s94 IHTA, the participator can claim Business Property Relief (BPR) on the attributed transfer if the close company qualifies as business property (s104-s112 IHTA). A trading company owned for at least 2 years qualifies for 100% BPR, reducing the attributed transfer to zero for IHT. However, from 6 April 2026 (Finance Act 2026), the combined 100% BPR and APR is capped at £1m per transferor per transfer. Attributed transfers above the £1m cap receive only 50% BPR — meaning 20% effective IHT on the excess. Investment companies (property portfolios, share dealing businesses) do not qualify for BPR — the full attributed transfer is taxable. The s112 IHTA excepted assets rule also removes excess cash and investment assets from BPR, even in otherwise qualifying trading companies.
How should close company directors report s94 and s98 IHT transfers?
S94 attributed transfers that constitute Chargeable Lifetime Transfers (CLTs — e.g., transfers to trusts) must be reported on form IHT100 within 6 months of the transfer date. IHT at 20% on the excess above the available NRB is due at that time. S94 attributed transfers that are Potentially Exempt Transfers (PETs — to individuals) are not reported during the donor's lifetime but are included in the estate's IHT400 return if the donor dies within 7 years. S98 transfers follow the same rules. The company itself should maintain detailed records of all relevant share capital alterations and connected-party transactions (board minutes, Companies House filings, valuation reports). HMRC can use powers under s219A IHTA to require information from the company. Failure to notify IHT events carries penalties under Finance Act 2007 Schedule 24.
What is the IHT planning priority for owner-managers of close companies post-FA 2026?
After Finance Act 2026 capped 100% BPR at £1m per transferor (combined with APR), owner-managers of valuable close companies should prioritise: (1) Keeping the company actively trading (qualifying for BPR — s105 IHTA). Any drift toward investment activities risks losing BPR entirely. (2) Lifetime gifting of shares: PETs of trading company shares are CGT-free (hold-over under s165 TCGA for gifts of business assets) and IHT-free after 7 years. BPR at the date of gift reduces the clawback risk in the 7-year window. (3) Considering an Employee Ownership Trust (EOT) for companies valued significantly above £1m: EOT transfers are IHT-exempt under s28A IHTA (not subject to the BPR cap) and CGT-free under s236H TCGA. (4) Ensuring annual close company transactions are at arm's length (avoiding s94 and s98 attributed transfers). (5) Reviewing wills to ensure company shares pass efficiently on death, with BPR claimed on the estate's IHT400.
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