Stanley: Taxation of Farmers and Landowners

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Source Currency: Issue 53 December 2023

Issue 53 includes:

- Farmland values continue to increase at [1.3]
- Tax treatment of Environmental Land Schemes (ELMs) at [1.4]
- Consultation on the taxation of environmental land management and ecosystem service markets and the 'gap' before the publication of the government's guidance at [1.13]
- Farming disputes: the farm residence (Teasdale v Carter [2023] EWHC 490 (Fam)) at [1.21]
- Farming disputes: unjust enrichment (Mate v Mate [2023] EWHC 238 (Ch)) at [1.23]
- Taxation of ELMs receipts: possible CGT implications and strategy whilst waiting for the guidance on the government's consultation on the taxation of ELMs and ecosystem service markets at [1.45]
- Impact of ELMs on farm stocks and work in progress at [3.1]
- Government's response to the Rock Review (GRRR) at [4.16]
- GRRR: implementing restrictions on landlords after taking land back in hand at [4.26]
- GRRR: new entrants to the tenanted sector and existing leases at [4.31]
- The end of the 'super-deduction' and the new 100% full expensing (FE) allowance at [5.30.1]
- Tax treatment of 'pop-up' camping on farmland as a result of change in planning law at [5.68]
- Full expensing (FE) choices at [5.78]
- Extended time limit for CGT assessments and claims following delayed completion of contract at [7.3]
- Land on which agri-environmental grants are received may be eligible for BPR at [8.32]
- VAT treatment of income from ELMs at [9.58]
- VAT treatment of working liveries at [9.154]
- SDLT: paddock let for horse grazing was found to be non-residential for SDLT purposes at [10.32]
- Tax consequences of planting trees as part of a development contract at [13.24]
- Pressure on farm probate valuations as a result of the reforms to farming such as long-term ELM contracts and farming to improve the environment at [16.40]
- Impact of the LURB (Levelling Up and Regeneration Bill) at [17.5]
- Contract Farming Arrangements: the need to review and ensure agreements are more robust following the Rock Review and the introduction of ELMs at [17.41]


 Julie Butler Author
 Malcolm Gunn Author