Section 268 IHTA - for details, see Chapter 14 of the
Inheritance Tax Manual IHTM14821 - provides that a composite
transfer of value may be effected by a series of "operations". E.g.
A gives 300 (out of his 1000 shares: ISC 1000 shares) to Mrs A, on
condition that she gives them to their son. A then gives 300 shares
to the son, and so does Mrs A. Under s.268 IHTA, these transactions
can be treated as constituting a gift of 600 shares by A to the
son.
If you become aware of such a transaction, you should
consult the IHT caseworker as to whether the associated operations
provisions have been brought into play, and, if so, with what
effect on SAV's valuation requirements.
| Additional Guidance: SVM150000 |
