Loose Ends

Milk quota and a 'fungible' asset
It is understood that the Revenue takes the not unreasonable view that milk quota is a fungible asset. It is worth considering what benefit this could have to the farmer.
The Capital Gains Manual (at paragraph CG77821) states that a producer primarily holds milk quota to produce and sell milk profitably and not run the risk of financial penalty. The manual states that such producers do not ordinarily buy and sell quota in the course of their day-to-day trade. Quota is an enduring capital asset of the business in the same way as buildings or farm machinery. Thus where some of a producer's quota was allocated without cost in 1984 and some was subsequently purchased the Revenue originally considered that the acquisition cost should be apportioned under section 52(4) Taxation of Chargeable Gains Act 1992 by reference to the...