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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Lifetime transfers: associated operations: the subjective test

If you have considered the objective test (IHTM14823) and determined that it does not apply, you must then consider the subjective test set out in IHTA84/S268(1)(b). To be relevant associated operations for the subjective test, there must be two or more operations (IHTM14826), of which

  • one is effected with reference to the other, or
  • one is effected with a view to enabling the other to be effected, or
  • one facilitates the effecting of the other.

If one of the operations is similarly linked to a further operation, all the operations are associated.

If none of the above conditions are met and the objective test (IHTM14823) has also not been met, then the operations are not associated operations.