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Home / Simons-Taxes /IHT, trusts and estates /Part I7 Special reliefs /Division I7.1 Business property relief (BPR) /Meaning of relevant business property / I7.111A Meaning of 'quoted' and 'control' for BPR
Commentary

I7.111A Meaning of 'quoted' and 'control' for BPR

IHT, trusts and estates

For BPR purposes 'quoted' and 'control' have their own meanings.

Quoted

'Quoted' for these purposes means listed on a recognised stock exchange and so 'unquoted' means securities not so listed on a recognised stock exchange1.

'Recognised stock exchange' is defined in ITA 2007, s 1005 'for the purposes of the Income Tax Acts'. HMRC will use the same definition for IHT purposes.

HMRC maintain two lists. A list of the countries where any stock exchange in that country is a 'recognised stock exchange' (designated countries) and a list of designated recognised stock exchanges.

The Alternative Investment Market (AIM) is for these purposes not a recognised stock exchange and so AIM shares are unquoted for BPR purposes.

American Depository Receipts (ADRs) (sometimes known as American Depositary Shares (ADSs)) are usually listed on a US stock exchange and so are treated by HMRC as listed and quoted for BPR purposes accordingly2.

Occasionally, shares in unquoted companies can be represented by ADRs and then the position is more complicated and will

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