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A quota question

09 February 2006
Issue: 4044 / Categories: Forum & Feedback , Income Tax
I have read with interest the article by Nigel Popplewell ('Partnerships revisited', see Taxation, 6 March 2003, page 549) together with further queries ('Milk quota') raised in Taxation, 7 October 2004, page 26.

The original article by Mr Popplewell generated some activity in this area which seemed to lessen after reference to various complications namely the then anticipated introduction of the single farm payment.
With the passing of time would readers please clarify that for say a mixed dairy farm it would now make good tax sense to introduce a limited company as a partner into an existing partnership and for the milk quota to be sold by the partnership and to be repurchased by the limited company so as to obtain tax relief on it as an intangible asset.
Will readers please confirm that this will not cause any problems with respect to the following.

  • The single farm payment.
  • The Thomsen case (i.e. is it possible for the company to be treated as a non-producer?)
  • Settlement/Arctic Systems...

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