The third element in IHTA 1984, s 10 is the repeated use of the word transaction. Section 10 applies to dispositions, including omissions, but the protection of IHTA 1984, s 10 will be lost if it is part of a transaction intended to confer a gratuitous benefit on someone or if it was made in a transaction which fails to satisfy the criteria considered in I3.143. The term transaction is widened to include a series of transactions and any associated operations1, and a disposition is itself defined2 as including a disposition effected by associated operations.
The notion of a series of transactions and any associated operations raises the question whether the word 'and' limits associated operations to the particular transaction with which they are associated or whether the words are
To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to Tolley+™ Research or register for a free trial
Web page updated on 17 Mar 2025 13:52