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HMRC internal manual

Inheritance Tax Manual

Lifetime transfers: associated operations: successive settlements

In Hatton v IRC [1992] STC 140, there was a settlement made on one day, followed on the next day by a second settlement (by a different person) of the reversionary interest under the first settlement.

It was accepted by Chadwick J that, on the facts, the first settlement was made ’with a view to enabling or facilitating the making of the second settlement’.

The two settlements were associated operations and so constituted a single disposition under what is now IHTA84/S268. Applying what is now IHTA84/S43 (2), the two settlements may be treated as a single settlement made by the settlor of the first settlement.