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HMRC internal manual

Inheritance Tax Manual

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HM Revenue & Customs
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Lifetime transfers: associated operations: definition of terms

Operation

Under IHTA84/S268(1) the term ‘operation’ expressly includes an omission but is otherwise undefined. It applies to all forms of dispositions (IHTM04023), for example a gift, a sale, a purchase or an exchange.

You can also consider the term to extend to wider activities such as making of a will or the exercise of votes as a controlling shareholder at a company meeting. However it does not cover automatic events like birth, death or the attainment of any specific age.

Disposition

The term ‘disposition’ - which is otherwise undefined - is extended by IHTA84/S272 to include a disposition effected by associated operations.

The concept of ‘associated operations’ therefore may be relevant whenever the extent of the inheritance tax charge depends on the identity of a disposition.

So, bear it in mind particularly when considering what constitutes a transfer of value or a settlement for the purposes of inheritance tax.

Transaction

The term ‘transaction’, where it is used in IHTA84/S10, includes associated operations - IHTA84/S10(3). Where it is claimed that a transaction is within IHTA84/S10, the S10 conditions must be satisfied not only for the individual transaction being considered, but also for the whole series of transactions - see IHTM04164.