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Chapter IHTM24040

Document Cited authorities 1 Cited in Related
Vincent
Published date20 March 2016
Record NumberIHTM24040
CourtHM Revenue & Customs
IssuerHM Revenue & Customs

Where agricultural property (IHTM24030) is transferred at a time when it is subject to a binding contract for sale, agricultural relief is not due unless the sale is to a company and is made wholly or mainly in consideration of shares or securities which will give the vendor control of that company, IHTA84/S124 (1).

Where the property transferred is a shareholding that is subject to a binding contract for sale, relief is not due unless the sale is made for the purposes of reconstruction or amalgamation, IHTA84/S124 (2).

But, where a transferor enters into a binding contract for sale of agricultural property for less than full consideration and that transaction itself gives rise to a claim for tax, that claim may qualify for relief. Subject to other statutory conditions...

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