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HMRC internal manual

Inheritance Tax Manual

HM Revenue & Customs
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Lifetime transfers: The remaining agricultural property

This test is applied immediately before the death, but by reference to transferee’s estate. The original property must qualify as agricultural property (IHTM24030) without regard to other assets that might form part of the deceased transferor’s estate. You need to look at the circumstances that prevail in the transferee’s estate and apply the usual range of tests to establish that the property is still agricultural property. So, if the transferee has changed to using the land for non-agricultural purposes, it is unlikely that agricultural relief will be available. (IHTM24180)