Readers' forum: Investment management

My client is a private limited company which is registered in the UK and operates here. It carries on the business of investment management and does this by the creation of funds consisting of directly held non-UK equities. It actively manages these funds through open-ended investment companies (OEICs) and undertakings for collective investment in transferable securities (UCIT) OEICs. These OEICs comprise publicly traded equities of companies – in any industry trading or investment – of a foreign country.

The funds are offered as investments to third parties and the company generates its fees from such offerings.

My question is whether the shares in my client company (not the shares in the OEICs) will be eligible for inheritance tax business property relief? On the other hand will they be precluded by IHTA 1984 s 105(3) or will the exclusions in s 105(4) or s 105(4A) apply?

I should be grateful for...