Section 234 — Inheritance Tax Act 1984: Interest on instalments.

Interest on instalments. 234 1 Where tax payable on the value transferred by a chargeable transfer—

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

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 that 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 ( as defined in section the 1159 of and Schedule 6 to Companies Act ) of one or more companies not falling within paragraph (a) above; 2006 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 ii which is of a description set out in regulations under section 107(5) of the Finance Act 1986.

4 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.