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HMRC internal manual

Inheritance Tax Manual

Lifetime transfers: associated operations: definition

The definition of associated operations is contained in IHTA84/S268. In general terms, operations (IHTM14826) may be associated if they affect the same property or form a chain of linked operations.

The operations may

  • take place at different times
  • be a number of steps taken at the same time
  • not necessarily have to be made by the same person
  • be an omission to do something.

You must specifically consider two alternative tests to determine whether separate events are associated operations. One of these tests must be satisfied if the associated operations provisions are to apply.

  • The (first) objective test (IHTM14823) looks at the relationship between items of property affected by the events - IHTA84/S268(1)(a).
  • The (second) subjective test (IHTM14824) looks at the relationship or connection between the events concerned - IHTA84/S268(1)(b).