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Legal Terms - Associated Operations
The *transfer of value is calculated by considering the combined effect of two or more operations.
Subject to inheritance tax. In these instances, the transfer of value is quantified as the decrease in the total worth of the estate resulting from the combined effect of the different actions (as defined in section 268 of the Inheritance Tax Act 1984). Case law illustrates that the occurrence of operations simultaneously or the performance of comparable activities by different individuals does not establish an association between them (Macpherson v IRC [1988] 2 All ER 753 (HL)). In order for two operations to be connected, they must either pertain to the same property (as stated in the Inheritance Tax Act 1984 § 268(1)(a)), or one operation must rely on the other, as seen in the case of Rysaffe Trustee Co (CI) v IRC [2003] EWCA Civ 356.
The *transfer of value is calculated by considering the combined effect of two or more operations.
Subject to inheritance tax. In these instances, the transfer of value is quantified as the decrease in the total worth of the estate resulting from the combined effect of the different actions (as defined in section 268 of the Inheritance Tax Act 1984). Case law illustrates that the occurrence of operations simultaneously or the performance of comparable activities by different individuals does not establish an association between them (Macpherson v IRC [1988] 2 All ER 753 (HL)). In order for two operations to be connected, they must either pertain to the same property (as stated in the Inheritance Tax Act 1984 § 268(1)(a)), or one operation must rely on the other, as seen in the case of Rysaffe Trustee Co (CI) v IRC [2003] EWCA Civ 356.
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