If a disposition (IHTM04023) satisfies the conditions of IHTA84/S11 (1) – (4) to only a limited extent, you should treat it as comprising two separate dispositions. The part which satisfies the conditions of S11 (1) – (4) is a disposition which is not a transfer of value (IHTM04024). The other part is a separate disposition which is a transfer of value and so may be chargeable.

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