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Home / Simons-Taxes /IHT, trusts and estates /Part I2 Statutory interpretation /Division I2.2 Form and substance of transactions /Form and substance of transactions / I2.212 The Ramsay principle, IHT and the associated operations rule
Commentary

I2.212 The Ramsay principle, IHT and the associated operations rule

IHT, trusts and estates

IHTA 1984, s 268 defines what are associated operations (subs (1)); provides two specific exclusions (subs (2), and then deals with the effects of operations being associated in a provision (subs (3)), which treats all the associated operations as one (the unification rule); provides that these operations shall be treated for tax purposes as occurring at the time of the last of them (the timing rule), then provides relief for earlier transfers subsumed in the scheme (the credit rule), but with an exception for transfers between spouses (the exception to the credit rule). These matters are considered further

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