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A disposition includes all those effected by associated operations¹. Where operations are associated, their combined effect on the value of the transferor's estate will be taken into account in determining whether there is a transfer of value and, if there is a transfer of value, what the value transferred by it is.

Whether associated operations make up a disposition is also relevant to:

1. Ìý

   •ÌýÌýÌýÌý what property is disposed of (an issue relevant to the relief available for various types of property)

2. Ìý

   •ÌýÌýÌýÌý whom the property is disposed (an issue relevant to the exemptions available for particular transfers eg, to a spouse)

3. Ìý

   •ÌýÌýÌýÌý the availability of exemptions

4. Ìý

   •ÌýÌýÌýÌý the meaning of 'settlement' (see I5.111, I5.118)

Where a controlling shareholder with a 60% holding in a company gives half of the holding to his son, having first transferred half to his wife who subsequently also transfers the shares to the son, the effect is to pass a controlling shareholding from father to son. HMRC would use the associated operations provisions