Belgium

  • % rented: c. 67% private rented (stable).
  • Agricultural policy: Common Agricultural Policy (CAP) – Belgium adopted a historic model for decoupling but retains the coupled suckler cow premium.
  • Tenure control: There is legislation for all leases of more than one year. Leases are generally for nine or 18 years, but can be ‘career’ up to age 65. Tenants have a pre-emptive right to buy and can pass leases to family members. Rent levels are controlled. Local land consolidation mechanisms exist.
  • Tax: Lightly taxed based on cadastral survey value [which shows the extent, value and ownership of land] not actual income. Income from renting out is taxed (but career leases are exempt). Property tax is paid annually by owner not tenant but based on nominal income. High tax rates for buying land.
  • New entrants policy: Inheritance is the normal route. Soft loans are offered to assist generations to buy-out. These are also available to new entrants but a lack of land supply is problematic.

    • Canada

  • % rented: 24% private rented (increasing), 13% state lease, 3% cropshare.
  • Agricultural policy: Active promoter of liberalisation of farm trade but quotas and price support on dairy, eggs and poultry. Support offered to farmers to even out farm income levels e.g. disaster recovery.
  • Tenure control: Dominant owner occupation reflects colonial land allocations. Private leasing relatively unregulated, subject only to fairly generic contract law. Leasing of Crown land regulated more tightly with rents linked to land value or profitability of enterprises and security of tenure. Specialist lenders support buying farmland. Controls on foreign ownership of land.
  • Tax: Tax liability varies across Canada. Range of tax advantages to farmers e.g. lower property tax, and no capital gains tax if structured appropriately.
  • New entrants policy: Inheritance normal route. Interest rates capped on all farm loans and young farmers allowed access to loans of up to 90% of price (80% for older farmers). Tax exemptions ease inter-generational transfers of assets.

    • Denmark

  • % rented: 34% private rented (increasing).
  • Agricultural policy: CAP - Decoupling implemented with clear expectation of move to flat rate (from 2014). Coupled payments retained for beef sector and sheep sector.
  • Tenure control: Long tradition of small owner-occupied farms. Leases relatively unregulated with rents set by market, maximum term of 30 years and no right of renewal. Limits of number of leases held by one farmer (five) and on distance between land (10km). Controls on maximum farm sizes and number of farms held only recently relaxed. Ownership restricted to EU nationals and generally has residency requirements. Local land consolidation mechanisms [a rearrangement of land parcel ownership to prevent fragmentation].
  • Tax: No concessional rates for farming.
  • New entrants policy: Inheritance normal route. Formal contractual succession between generations is recognised and supported by staggering purchase of land and assets. Still high cost/debt despite soft loans for up to 70% of purchase price and bespoke savings accounts.

    • France

  • % rented: 67% private rented (stable)
  • Agricultural policy: CAP – historic model for decoupling but also maximum coupled support for beef, sheep, goat and arable.
  • Tenure control: Land market heavily regulated by ‘Safer’. [French Government land agency]. Main aim is to settle young farmers and support land/farm consolidation. Safer have pre-emptive right to buy and reallocate any land. Code Rural entitles a tenant to a minimum term of nine years although longer and career terms are possible. Tenants entitled to renew lease or to succeed. Improvement recognised and compensation payable by landlord. Pre-emptive right to buy if owner decides to sell. Rental values and land prices controlled.
  • Tax: Tax is paid on property by owner (although proportion can be paid by tenants – up to 20%). Fifty per cent tax discount to young farmers for first five years. Land transfers (outwith Safer) are taxed but for young farmers this is set at 0.715%.
  • New entrants policy: Safer system installed 1230 with 65% of these outwith farming families in 2012. (Still on 0.2% of holdings).

    • Inheritance normal route.

    Hungary

  • % rented: 60% private rented (economy in transition)
  • Agricultural policy: CAP since 2004 but ten-year transition arrangements. Decoupled Pillar 1 payments but some coupled payments offered.
  • Tenure control: Redistribution of land during 1990s under Compensation Acts. Leasing of private land through contract law. Tenant has first refusal on lease expiring but no automatic renewal. Pre-emptive right to buy for tenants and neighbours (with price controls). Ban on EU nationals owning land will be lifted in 2014 but buyers still have to comply with eligibility criteria of working in agriculture and farming the land. Corporate purchases are forbidden. Limits on area (300ha purchased and 1200ha leased). Land Fund in place to encourage voluntary exchange but also compulsory purchase to configure land better.
  • Tax: No special provisions for agriculture or rental income from land. Land sales subject to 2% transfer tax, local taxes and capital gains tax.
  • New entrants policy: Land availability probably not an issue but support for new entrants offered due to competition from greater bidding power of incumbent farmers and foreign new entrants.

    • Netherlands

  • % rented: 41% private rented (slight rise)
  • Agricultural policy: CAP – shift to flat rate expected to favour arable farms. Coupled payment retained within beef sector plus starch potato sector.
  • Tenure control: Leases were heavily regulated but increasingly liberalised with unregulated leases of less than six years now permitted. Tenure controls currently being reviewed. Maximum rents are regulated. Local and consolidation mechanisms [a rearrangement of land parcel ownership to prevent fragmentation.
  • Tax: No concessions to farmers. All businesses have flexibility to offset losses against income tax and exemptions for inheritance tax to facilitate succession.Land purchase taxed at 6% unless land remains in agricultural use for ten years.
  • New entrants policy: Inheritance is main route. Land price high and supply limited. No specific policy measures beyond education and training. Maatchap (partnership) working allows phased transition for a younger farmer to take over from a parent (or other) with staggered purchase of land and assets.

    • New Zealand

  • % rented: 5% private rented, 15% Crown leases (no official data but probably stable).
  • Agricultural policy: Free market approaches in all sectors apart from natural disasters. High degree of supply control in cooperatives is permitted.
  • Tenure control: Dominant owner-occupation reflects colonial land allocation and explicit policy of favouring family farms. Private leases regulated by contract law only. Crown leases more tightly regulated, with rent controls, good security and (mostly) pre-emptive rights to buy. Constraints on foreign ownership of land remain.
  • Tax: Agriculture treated as other businesses although some allowances for livestock valuation and potentially for farm enrolment in the GHG [greenhouse gas] emissions trading scheme.
  • New entrants policy: Not seen as an issue. Share-farming is important but under pressure from other entry routes as entry costs rise.

    • Norway

  • % rented: 58% private rented (increasing).
  • Agricultural policy: Focus on improved productivity and raising incomes. Emphasis on deregulation and market orientation.
  • Tenure control: Policy and legislation actively sought to maintain small family farms. Farms have got bigger generally through renting of land as current owners exit the industry but retain ownership. Presumption of family succession to land is difficult to overcome and residency and active management obligations generally preclude purchase by companies, institutions and absentee landlords.
  • Tax: High allowance on farms means most pay little tax. Land passing through families is exempt from capital gains tax. Stamp duty is paid on all transfer but inherited land is valued lower for tax purposes and inheritance tax can be paid in interest-free instalments.
  • New entrants policy: No policy measures. The tax advantages favour inter-generational transfer. State pensions can be paid from 62 if an experienced farmer transfers the farm to somebody else.

    • Poland

  • % rented: 20% mostly State leased (economy in transition).
  • Agricultural policy: CAP since 2004 but 10-year transition arrangements. Favour fully decoupled payments under CAP reform.
  • Tenure control: Highly fragmented private ownership persisted during Communist era and remains dominant. Maximum area of 300ha and requirement for purchasers to have agricultural qualifications and farmed locally for five years which restricts foreign ownership. Pre-emptive right to buy for individuals with leases over three years. Leased land almost entirely from State to large co-operative and corporate entities. Leases for 10-30 years, with controlled rents.
  • Tax: [Started] paying income tax from 2014 rather than agricultural property tax based on a nominal value. Sale of agricultural land is exempt from capital gains and sales taxes provided land remains in production and is not sold again within five years.
  • New entrants policy: Relatively high proportion of young farmers. Inheritance is normal route. Soft loans to new farmers buying land. Also used Pillar II to support with capital grants and early retirement schemes. State (APA) will buy holdings in return for providing a pension annuity to older farmers – but limited funding.

    • Ireland

  • % rented: 11% private rented (increasing).
  • Agricultural policy: CAP will have to move to flat rate system from 2014. Retained partial coupling of beef payments.
  • Tenure control: Historically significant state intervention in land markets led to domination of owner-occupation. Leases largely unregulated and subject to market forces.
  • Tax: Farm income taxed as any other business. Tax exemptions of income from leasing out land increase with length of lease. Land subject to capital gains tax, stamp duty and inheritance tax but retirement tax relief if older farmers transfer ownership early.
  • New entrants policy: Inheritance is main route. Previous instances of early retirement schemes and installation grants proved ineffective. Now have retirement tax relief and encourage collaborative farming approaches.