In many cases, shares will qualify for 100% BR so that the question of the availability of instalments is irrelevant. In all cases where 100% BR is not available, the availability of the instalment option and interest relief should be considered and reported to the IHT caseworker unless a case is clearly sub-threshold.
The instalment option applies to any shares or securities which contributed to control, determined as for business relief, immediately before the chargeable transfer (s.228 (1)(a) IHTA 1984).
In other cases the option is available in respect of shares (but not securities) where:
•the value transferred, after any business relief, exceeds £20,000 and