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HMRC internal manual

Business Income Manual

Farming quotas: purchase and sale of quotas

S33 Income Tax (Trading and Other Income) Act 2005, S53 Corporation Tax Act 2009

Quotas may be transferable between farmers by outright sale and purchase. As the quota is normally a fixed capital asset of a farmer’s trade (see BIM55305), such transactions normally have no trading profits consequences for the farmers concerned. In particular, there can be no question of farmers who have bought a quota claiming a deduction for the amount of any expenditure in place of levies or leasing charges which they would have incurred if they had not bought it. As regards Capital Gains Tax, see CG77701 onwards.