BPR Qualifying Shares and Inter-Spouse Transfers

[jokerman]

Hi - would appreciate views on the following.

Person A transfers/gifts 1 million of BPR-qualifying shares to their Spouse, person B - say in July 2025. They have been held for 2+ years by Person A.
Person B dies within 2 years of the gift.

Is there any IHT to pay here?

The whole point in the transfer would be so that each person is able to utilise their 1million BPR allowance. But is there a risk that, within 2 years, the shares don't now qualify for BPR at all as they haven't been owned by the recipient for 2 years at the point of death of Person B.

Thanks in advance.

[bd6759]

S109(1) of the 1984 Act.