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Chapter BIM55105

Document Cited authorities 3 Cited in Related
Vincent
Published date22 November 2013
Record NumberBIM55105
CourtHM Revenue & Customs
IssuerHM Revenue & Customs

S221-S225 Income Tax (Trading and Other Income) Act 2005 (ITTOIA 2005), S996(1) Income Tax Act 2007, S36 Corporation Tax Act 2009, S1125 Corporation Tax Act 2010

To fall within the statutory definition of `farming’ (see BIM55051), the produce of the activity must have some husbandry origin in the land occupied by the person carrying on the activity. Thus, an intensive enterprise, in which livestock are kept entirely separate from the land (for example entirely indoors or, in the case of fish, in tanks), and fed entirely on purchased feed, is not farming (see Lean & Dickson v Ball [1925] 10TC341, Jones v Nuttall [1926] 10TC346, and Peter Reid v CIR [1947] 28TC451).

However, for the purposes of the averaging provisions of S221-S225 ITTOIA 2005 the definition of `farming’ is extended to include the intensive rearing of livestock or fish on a commercial...

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