Section 234 Interest on instalments.

United Kingdom

Where tax payable on the value transferred by a chargeable transfer—

(a)

is payable by instalments under section 227 above and is attributable to F1—

(i)

value treated as reduced under Chapter 1 or 2 of Part 5 of this Act, or

(ii)

the value of any shares, securities, business or interest in a business, if that value is not treated as reduced under either Chapter of that Part, or

(b)

is payable by instalments under section 229 above,

it shall, for the purposes of any interest to be added to each instalment, be treated as carrying interest from the date at which the instalment is payable.

(2)

Subsection (1) above shall not apply to tax attributable to the value of shares or securities of a company falling within paragraph (a) of subsection (3) below F2that is not tax attributable to value treated as reduced under Chapter 1 or 2 of Part 5 of this Act unless it also falls within paragraph (b) or (c) of that subsection.

(3)

The companies referred to in subsection (2) above are—

(a)

any company whose business consists wholly or mainly of one or more of the following, that is to say, dealing in securities, stocks or shares, land or buildings, or making or holding investments;

(b)

any company whose business consists wholly or mainly in being a holding company (F3as defined in section F41159 of and Schedule 6 to the F5Companies Act F62006) of one or more companies not falling within paragraph (a) above;

F7(c)

any company—

(i)

whose business is wholly that of a market maker or is that of a discount house and (in either case) is carried on in the United Kingdom, or

C3(ii)

which is of a description set out in regulations under section 107(5) of the Finance Act 1986.

C4(F84)

In this section “market maker” means a person who—

(a)

holds himself out at all normal times in compliance with the rules of The Stock Exchange as willing to buy and sell securities, stocks or shares at a price specified by him, and

(b)

is recognised as doing so by the Council of The Stock Exchange.

Annotations

Textual amendments

F1

Words in s. 234(1)(a) substituted (with effect in accordance with Sch. 12 para. 17 of the amending Act) by Finance Act 2026 (c. 11), Sch. 12 paras. 13(2)(a), 17

F2

Words in s. 234(2) substituted (with effect in accordance with Sch. 12 para. 17 of the amending Act) by Finance Act 2026 (c. 11), Sch. 12 paras. 13(2)(b), 17

F3

Companies Act 1989 s. 144(4)and Sch. 18 para. 30(4)with effect from the appointed day—on and after 1November 1990 (S.I. 1990 No. 1392).Originally

“within the meaning of”.

F4

Words in s. 234(3)(b) substituted (1.10.2009) by The Companies Act 2006 (Consequential Amendments) (Taxes and National Insurance) Order 2009 (S.I. 2009/1890), art. 4(1)(f)

F5

Companies Consolidation (Consequential Provisions) Act 1985 (c. 9, SIF 27), Sch. 2,with effect from 1July 1985.Originally

“Companies Act 1948”.

F6

Words in s. 234(3)(b) substituted (1.10.2009) by The Companies Act 2006 (Consequential Amendments) (Taxes and National Insurance) Order 2009 (S.I. 2009/1890), art. 4(1)(f)

F7

S. 234(3)(c) substituted (with application in accordance with reg. 2 of the amending S.I.) by The Inheritance Tax (Market Makers and Discount Houses) Regulations 2012 (S.I. 2012/2903), regs. 1, 5

F8

Finance Act 1986 s. 107(2),in relation to events on or after 27October 1986“the day of The Stock Exchange reforms”—(as defined in s. 106(8)and s. 107(8)).

Modifications

C1: S. 234(1) applied (with effect in accordance with Sch. 10 para. 9 and with application in accordance with Sch. 10 para. 10(1) of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 10 para. 10(3)
C2: S. 234(1) applied (with modifications) (with effect in accordance with s. 30(9)-(12) of the amending Act) by Finance (No. 2) Act 2017 (c. 32), s. 30(15)
C3: S. 234(3)(c)(ii) modified (with application in accordance with reg. 2 of the amending S.I.) by The Inheritance Tax (Market Makers and Discount Houses) Regulations 2012 (S.I. 2012/2903), regs. 1, 7
C4: S. 234(4) amended (6.1.1993) by S.I. 1992/3181, reg.4 (as amended (1.12.2001) by S.I. 2001/3629, art. 135)

Notes on the whole Act

Textual amendments

F1: By Finance Act 1986 s. 100(1), on and after 25 July 1986 the Capital Transfer Tax Act 1984 may be cited as the Inheritance Tax Act 1984.