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HMRC internal manual

VAT Taxable Person Manual

Particular trades: Share farming and the husbandry of crops: Agreements where the landowner engages a contractor to supply husbandry services

If your landowner is not granting the contractor or merchant a right over land or a licence to occupy land for the purpose of growing a crop (as discussed in VTAXPER74200), you must ask whether the agreement represents the reverse situation: is the landowner not making a supply of the land, but calling in a contractor to supply services of husbandry? These types of agreement are characterised by a lack of equality between the landowner and the contractor. They tend to talk of the landowner “appointing” the contractor to manage the land in order to maximise profits for the landowner, and emphasise that the landowner will issue instructions upon which the contractor must act. These instructions may stretch to the gathering and marketing of the crop, but this is always on behalf of the landowner who owns it.

In this situation there is no exempt supply of land by the landowner. The contractor makes a standard-rated supply of husbandry services to the landowner, and the landowner is accountable for any tax on the final supply of the crop. If the contractor supplies seed or fertiliser and makes a separate charge for these, this is a separate supply of goods which will follow the liability of the goods in question.