Readers' forum : Branching out

I act for a father and son farming partnership. Some of the land that is owned personally by the father and used in the partnership may currently carry some hope value and could start to show some significant development value in the future. A proposal to transfer the land into a trust is being considered. Holdover relief would be available for capital gains tax purposes but the transfer would be a chargeable lifetime transfer for inheritance tax purposes. Agricultural property relief will be available against 100% of the agricultural value of the land and business property relief will be available against 50% of the non-agricultural value.

I am wondering whether it would be possible to transfer the land into the partnership and hold it for at least two years before transferring it into a trust when it would then qualify for 100% business property relief.

My concern is that ...