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HMRC internal manual

Inheritance Tax Manual

From
HM Revenue & Customs
Updated
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Lifetime transfers: associated operations: the objective test

When considering if the associated operations provisions apply to a series of operations (IHTM14826) you should firstly apply the objective test set out in IHTA84/S268(1)(a). To be relevant associated operations for the objective test, the two or more operations must be

  • operations which affect the same property, or
  • operations, one of which affects some property and the other(s) affects

    • property which represents the first property, or
    • income arising from that property, or property which represents accumulated income from the property.

If the operations do not qualify under the objective test, consider the subjective test. (IHTM14824)