associated operations

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Two or more operations that are considered in terms of their combined effect when calculating the transfer of value chargeable to inheritance tax. In such cases the transfer of value is measured as the reduction in the estate caused by the various operations considered in aggregate (Inheritance Tax Act 1984 s 268). Case law demonstrates that operations are not associated merely by virtue of taking place at the same time, nor by different persons choosing to perform similar acts. For two operations to be associated, it would appear that, either, the two operations concern the same property (Inheritance Tax Act 1984 s 268(1)(a) or one operation is dependent on the other (Rysaffe Trustee Co (CI) v IRC [2003] EWCA Civ 356, [2003] STC 536).

Subjects: Law.

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