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I3.114 The meaning of 'disposition' for IHT

The concept of disposition is quite distinct from that of causing loss. Thus there can be a disposition which does not cause loss (a sale for full value in cash) and an event which causes loss but which does not amount to a disposition (the accidental destruction of an asset). Neither of these events can give rise to a transfer of value under this general definition.

Dispositions are defined as including dispositions effected by associated operations (see I3.115)¹. Certain types of disposition, such as commercial transactions, maintenance of family, are expressly excluded from being transfers of value (see I3.141–I3.160).

The following do however fall within the definition of a disposition:

1. Ìý

   •ÌýÌýÌýÌý failure to exercise a right (see I3.117)

2. Ìý

   •ÌýÌýÌýÌý certain life policies issued in respect of an insurance policy (see I3.118)

3. Ìý

   •ÌýÌýÌýÌý alteration in a close company's capital (see I3.119)

4. Ìý

   •ÌýÌýÌýÌý property ceasing to be subject to a reservation during the donor's lifetime (see I3.119A)

Special rules