· S43 does not change the law of trusts. Cannot change 5 separate trusts into a single settlement.
· Could not be treated as associated operations- only if all contribute to overall transfer of value, but not where each and every one of them already constitutes a transfer of value in and of itself.
· a taxpayer established 5 mirror discretionary settlements- in each case Bs and Ts were the same. Each comprised £10 and private co shares were subsequently added to each trust. The settlements were dated on different days.
· Park J
· The practical operation of the associated operations provisions is comparatively limited. It is not some sort of catch-all anti-avoidance provision which can be invoked to nullify the effectiveness of any scheme or structure which can be said to have involved more than one operation and which was intended to avoid or reduce IHT.