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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Lifetime transfers: associated operations: why are the provisions necessary?

Inheritance tax is charged on the value transferred by a chargeable transfer IHTA84/S1 (IHTM04021). The basic scheme of the legislation mainly focuses on a particular transfer made by a particular person. When looking at chargeable transfers for Inheritance Tax, you consider the loss to the estate on each disposition (IHTM04054). This can give an opportunity to avoid tax through artificially splitting an intended transfer into a number of dispositions.


Tina has a 100% shareholding in ABC Ltd. At 11 June 2011 it is valued at £100,000.

Tina transfers

  • a 33% holding to Steven on 11 June 2011
  • a 33% holding to Steven on 12 June 2011 and
  • a 34% holding to Russell on 13 June 2011

Following Tina’s death in August 2011, the loss to the estate on each transfer is individually valued at

  • £43,000
  • £26,000, and
  • £17,000 respectively.

A total of £86,000

The total of the individual transfers for Inheritance Tax (IHT) is only £86,000 but Tina had effectively given away £100,000 worth of assets.

The legislation at IHTA84/S268 counters this in certain circumstances so that you can look at the overall effect of several events through the concept of ’associated operations’.

The effect of associated operations is extended or limited in various areas of IHT legislation, as explained in the following pages.