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HMRC internal manual

Inheritance Tax Manual

Structure of the charge: what is a disposition?

The word disposition has its wide natural meaning and we regard it as

  • including all forms of disposals and transfers of cash and other property, and
  • including both the creation and the release or other extinguishment of any debt or other right enforceable against a person or his estate.

The legislation expressly defines disposition to include

  • a disposition effected by associated operations, (IHTM14822) IHTA84/S272
  • a person’s deliberate omission to exercise a right (IHTM14810) if that omission causes the value of

    • that person’s estate to diminish, and
    • another persons estate (or property held on discretionary trusts) to increase, IHTA84/S3 (3)
  • certain future payments (IHTM14871) made more than 12 months after a transfer for partial consideration, IHTA84/S262
  • an alteration of a close company’s share or loan capital, (IHTM04069) IHTA84/S98.

Some dispositions are expressly prevented from being transfers of value, see IHTM04151.