IHTM14836 - Associated operations: successive settlements

In Hatton v IRC [1992] STC 140, there was a settlement made on one day, followed on the next day by a second settlement (by a different person) of the reversionary interest under the first settlement.

It was accepted by Chadwick J that, on the facts, the first settlement was made “with a view to enabling or facilitating the making of the second settlement”.

The two settlements were associated operations and so constituted a single disposition under what is now IHTA84/S272 . Applying what is now IHTA84/S43 (2), the two settlements may be treated as a single settlement made by the settlor of the first settlement.