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HMRC internal manual

Inheritance Tax Manual

Lifetime transfers: associated operations: transfers involving relievable property

A transfer of property that qualifies for agricultural or business relief may be followed by an event which, if it had occurred before the transfer, would have prevented the relief being available.

Examples

  • Property which is entitled to agricultural relief is transferred and then sold by the transferee.
  • A transfer of unquoted shares/securities which are eligible for business relief is followed by the shares becoming quoted on a recognised stock exchange (IHTM18061), or being listed on the USM (IHTM18339).

A point to consider in these situations is whether relief, which is otherwise available, should be challenged by reference to the associated operations provisions.

You can find further guidance in the separate agricultural relief (IHTM24170) and business relief (IHTM25131) sections of the manual.