Stanley: Taxation of Farmers and Landowners

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Commentary

Source Currency: Issue 57, December 2025. Draft legislation published on APR/BPR reductions at para [1.2], EFRA (Environmental, Food and Rural Affairs) Committee request to delay APR/BPR changes ignored at para [1.2], Sustainable Farming Initiatives (SFI) success and closure at para [1.46], Barter of convenience at para [2.13], Disputes over farming share of profit at para [2.23], Shooting losses disallowed - MacDonald at para [2.116], The valuation of farm stocks at market value at para [3.75], The double cab pick-up update at para [5.30.2], The pre-development costs – Gunfleet - Court of Appeal at para [5.30.5], The FETF Grant and purchase of machinery at para[5.30.7], The ‘Tanner Hotel’ as part of farm tourist offering at paras [5.66] and [5.68], Restructuring farm diversification at para [5.78], Compulsory purchase orders and possible loss of hope value at para [5.91], Farm succession planning at para [5.104], Crisis management plan at para [5.105], Funding later life care - the funding’ hit list’ at paras [5.106] and [16.29] Director’s loan left uncollected by liquidator is not considered to be released or written off for tax purposes at para [6.41], HMRC’s 20% test for definition of substantial activities in relation to trading companies not accepted by the First-tier Tax Tribunal at para [7.83], Holiday business with full-time staff held not to qualify for business relief at para [8.33], Automatic accrual of partnership share to surviving partners does not prevent BPOR from applying at para [8.34], Agricultural relief applies to land occupied for agriculture the two years prior to the time of charge and ownership for that period is not required at para [8.70], The full IHT relief for heritage property should be considered where agricultural relief is limited to 50% at para [8.85], Double cab pick-up at para [9.28], Input VAT and private use at para [9.29], VAT and compulsory purchase at para [9.76], VAT on large marshmallows at para [9.140L], SDLT withdrawal of capital provision within three years of transfer of land to a partnership not considered to apply if the land itself is transferred back out at para [10.76A], Woodland held outside the UK at para [13.34], More conditional exemption IHT claims for national heritage land at paras [14.3] - [14.4], The need to review heritage property early at paras [14.28] - [14.30, The importance of farm valuations at para [16.43], Farm Wills - there must be one at para [17.40A], Harsh late payment penalties under MTD regime at para [19.35].

Contributors

 Julie Butler Author
 Malcolm Gunn Author