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HMRC internal manual

Company Taxation Manual

Particular bodies: farming

Farming is a major UK industry. Many farmers trade in partnership or alone as sole traders but some farming enterprises are undertaken by companies.

Historically, farming was taxed under Schedule B as income from the occupation of land, but sence 1949-50 (FA48/S31) the taxation of farmers, including companies, has been dealt with in accordance with the principles associated with the computation of trade profits, though there remain a number of important differences and peculiarities. These are summarised here but more detail can be found at BIM55000 onwards.

Farming is statutorily defined (CTA10/S1125 & ITA07/S996) and all farming carried on by one person is treated as one trade (CTA09/S36 & ITTOIA/S9). The implications of this are explained at BIM55050 onwards.

Many complications have arisen because of European Union grants, subsidies and quotas. The guidance in the BIM explains how to deal with these and includes appropriate cross references to the CG guidance material (BIM55150 onwards).

Stock valuations can also be problematical but an industry agreement first published as BEN19 but currently as helpsheet IR232 makes these easier to resolve (BIM55400 onwards).

Statute defines livestock as trading stock but there are exceptions including an opportunity to elect for the herd basis. These are explained at BIM55500 onwards.

Farmers can be restricted in the amount of loss relief they can claim under ITA07/S64 or CTA10/S37 by ITA07/S67 to S70 or CTA10/S48. This legislation is explained at BIM85600 onwards.

Recognising the natural fluctuation of farming profits, farmers (but not farming companies) may be able to claim to average two consecutive years’ profits. See BIM84055 onwards.

Farmers could claim Agricultural Buildings Allowance which was similar to Industrial Buildings Allowance. These allowances were abolished over a 4 year period ending in 2011. See FA08/S45. Agricultural buildings allowances are explained at CA40000 onwards.