Chapter IHTM14836
| Published date | 20 March 2016 |
| Record Number | IHTM14836 |
| Court | HM Revenue & Customs |
| Issuer | HM Revenue & Customs |
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/S268. Applying...
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