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ER on sale of farmland

Potential planning

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Hi all.

A client wants to sell farmland for developement (currently farmed as a sole trader).

I understand that as this is a part disposal of land and because the farming business isn't ceasing ER won't be available at present.

Would there be any issues with setting up a newco and the client then lending the land to the business to farm for a year before gifting say 10% of their shares to a family member and selling the land to a third party? I believe that this meets all of the assets used in a business rule but I was unsure if it would be caught by any anti-avoidance legislation.

Any help or advice would be greatly appreciated.


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