»Ê¹ÚÌåÓýapp

Where property given unconditionally by one spouse or civil partner (IHTM11032) to the other is subsequently transferred by the latter to a third party, you cannot use the associated operations provisions to attribute the transfer to the first spouse or civil partner.

»Ê¹ÚÌåÓýapp Chief Secretary to the Treasury assured Parliament that this would be HMRC’s practice, and it was publicised in a Press Release dated 8 April 1975.

However, where the transfer between spouses or civil partners is part of a more complex series of transactions which taken together are the way one of them makes a disposition to a third party, it may be more appropriate to use the associated operations to allocate the transfer(s) to the correct transferor.