§ Lord Donoughue
asked Her Majesty's Government:
Whether, if one of the qualifying alternative investment market shares entitled to 100 per cent inheritance tax relief and held for two years, is taken over for cash and net proceeds are reinvested in a similarly qualifying company, the investor loses all of the time benefits from the original holding; and [HL2214]
Whether an investor of shares traded on the alternative shares market can carry over time benefits from one holding to another new holding; and what is the time within which the proceeds must be reinvested to carry over the time benefits in order to maintain inheritance tax relief; and [HL2215]
Whether, if an investor of shares traded on the alternative shares market sells shares for one of the companies qualifying for relief from inheritance tax and the proceeds are reinvested in a similar qualifying company, the investor loses all the time benefits from the original holding. [HL2216]
§ Lord McIntosh of Haringey
The rules for inheritance tax business property relief provide for property to be replaced while maintaining entitlement to relief. The same rules apply to shares on the alternative investment market as to other property eligible for relief: where otherwise qualifying property has replaced other such property, it is entitled to business property relief if it and the property it replaced was owned for a total of at least two years during the five years immediately before the taxable transfer.