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HMRC internal manual

Business Income Manual

Farming in tax law: tax treatment of share farming agreements

S996(1) Income Tax Act 2007, S1125 Corporation Tax Act 2010

Both parties to a genuine share farming agreement may be accepted as farming (see BIM55051) as they have concurrent rights to the land and both are contributing to an undertaking of husbandry thereon (but see BIM55080 - BIM55085).

For guidance on the application of the herd basis in share farming cases, see BIM55640.