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One problem that has been discussed in connection with IHTA 1984, s 268 has been the use of arrangements to make use of other people's annual exemptions, or nil rate bands. Now that there is potential exemption (I3.311–I3.319) the use of annual exemption is of less interest, but on the other hand the nil rate band is much increased. There is also the desirability in some circumstances of channelling a gift through someone with a longer expectation of life, and with a better chance of surviving the seven years so as to make a potentially exempt transfer completely exempt.

The usual operation involves a spouse or civil partner and is designed to exploit the exemption for transfers between spouses or civil partners. The exclusion of the allowance under the associated operations rules for earlier transfers where a transfer to a spouse or civil partner is involved (see I3.262)