HMRC (Inheritance Tax Manual, IHTM04023) defines ‘disposition’ as having its ‘natural’ meaning and regards it as:

including all forms of disposals and transfers of cash and other property, and

including both the creation and the release or other extinguishment of any debt or other right enforceable against a person or his estate.

The legislation expressly defines ‘disposition’ to include:

(1)a disposition effected by ‘associated operations’ (IHTA 1984, s. 272: see ¶608-150 and IHTM14822);

(2)a person's deliberate omission to exercise a right (¶608-050) if that omission causes the value of (IHTA 1984, s. 3(3)):

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