Fears that agricultural relief was being used as a tax-efficient inter-generational wealth transfer mechanism for non-family farms were voiced in the Agri-Taxation Review as far back as 2014.

The concerns were raised in the stakeholder working group by Macra. As a result, it was recommended that agricultural relief would be targeted at “qualified or full-time farmers or to those who lease land out on a long-term basis”.

“There are concerns that the definition of ‘farmer’ for the purposes of the relief is not sufficiently robust to ensure that this relief is only being availed of by active, productive farmers,” the report stated.

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“There have also been suggestions that the relief is being used as a tax efficient inter-generational wealth transfer mechanism for non-family farms,” it added.

“Therefore, this relief will now only be available to those who are deemed ‘qualified’ or full-time farmers or those who lease land out on a long-term basis,” the report recommended.