Readers’ forum: Quarry question

My client inherited a working farm a couple of years ago and has been running it as a partnership with his sons. The farm is not overly profitable but the client also receives significant income from a quarry on the property. At present that income is declared on my client’s tax return and is subjected to higher rates of tax. The family would like to move the farm trade into a limited company (it is intended that our client will remain the majority shareholder) and then lease the land including the quarry to it. The company would then receive the income from the quarry. The client has already spoken to the quarry owners and they have said they would have no problem with the transaction.

The lease on the whole property would be drawn up to give vacant possession within 12 months so that inheritance tax agricultural...