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HMRC internal manual

Inheritance Tax Manual

Lifetime transfers: associated operations: additional provisions

As a general rule, it does not matter whether or not

  • the operations (IHTM14826) are effected by the same person or
  • they are effected simultaneously.

There are two exceptions from this general rule. These exceptions are set out in IHTA84/268(2). The exceptions are that

  • the granting of a lease for full consideration in money or money’s worth cannot be associated with an operation which occurs more than three years later.
  • an operation effected before 27 March 1974 cannot be associated with one which occurs on or after that date.