FARMING & RURAL BUSINESS COMMUNITY NEWS - May 2020 THE VIEW FROM THE CHAIR - ICAEW.com

FARMING & RURAL BUSINESS COMMUNITY NEWS
May 2020

THE VIEW FROM THE CHAIR

When I wrote the “state of the nation” article in December, I could see the industry and our
profession looking forward to a degree of normality after a fairly fraught year in 2019. I
used phrases like: “A stable basis for forward plans”, “Brexit boost” and “known risks” and,
if asked, I would have expected this newsletter to be commenting on Sajid Javid’s first
budget together with the progress of the Brexit negotiations and the Agriculture Bill.

As usual, I could not have been more wrong. We saw a change of Chancellor shortly
before the Budget, a Budget which was virtually devoid of fiscal changes – so much so that
one wondered if a couple of pages had fallen out of the speech on the way to the House of
Commons, and a pandemic which hit the world like a bolt from the blue and which has
triggered a wave of public expenditure from a Conservative government almost beyond
imagination. We have seen perhaps the deepest and sharpest recession since the 1930s,
30% wiped off world stock markets and a reduction in personal liberties which in many
respects goes beyond those seen during wartime.

As rural practitioners we may in fact be luckier than most. Many of our farms are owner
occupied or have small workforces who normally operate in open air, working largely
alone. They have very limited opportunities for coming into contact with infection and self-
isolation is pretty much part of their normal lifestyle. Arable farming in particular isn’t really
time sensitive so if someone is sufficiently fortunate as to only have mild symptoms lasting
for a week or so, it will be no more disruptive than a spell of wet weather - and frankly if
the weather is just right for drilling or spraying, they would probably rather be mildly ill in
the tractor than at home in bed. Those with more severe infections would probably find a
neighbour to help out. Livestock farmers might have more difficulties if they are
incapacitated, but at that level most will have some sort of cover for a few days. T The
bigger issues, which have particularly hit the milk sector but also more generally, are the
indirect impacts of supply chain disruption which may result in cancelled contracts, delays
in food leaving the farm and, indeed, problems with input deliveries coming into the
business. Certainly the support package which the Government have announced will be a
help to some, but one of the issues with such a diverse sector as agriculture is that whilst
part of the industry is carrying on almost as normal, other areas are suffering badly.

In the longer term the main group, outside the milk and livestock sectors, to face real
difficulty will be the fruit and vegetable growers who rely on large numbers of (often
foreign) workers. Travel restrictions and enhanced health protection measures are likely to
mean there are fewer available workers, and the job itself would take longer. Perhaps in
these strange times a land army will indeed be formed to bring in the harvest – in the days
when a hospital can be created in a fortnight, anything is possible.

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When we eventually come through this, the world may well look different. Under the forced
circumstances of self-isolation, teleconferencing has become mainstream, and the days
when delegates spent all day travelling across the country to attend a two hour meeting
may not return. Similarly, we can expect a changed attitude towards working from home,
balancing the wasted time spent commuting against possible efficiency losses from
working without the close support of colleagues. Perhaps we will even see a reappraisal of
globalisation, international outsourcing and “just in time” supply chains, all of which
contributed, in their different ways to the spread and impact of the pandemic.

Finally, of course, there will be a price to pay. Reference has already been made to this in
terms reappraising how the self-employed are taxed, and one might anticipate that when
the dust settles and the scale of the borrowing becomes apparent, other taxes may be
revisited. I suspect that the first post Covid Budget may have rather more fiscal content
than that unveiled last month.

On a more positive note, spring is now upon us, the weather has been kind and even
though many farms will be growing spring crops rather than winter, the prices are looking
up.

Looking back to December I see that I wrote ““In addition to the known risks, there are also
unknowns”. I seem to have hit the mark pretty accurately there.

Aloysia Daros

ARE CAP PAYMENTS CLASSED AS STATE AID?

From 6th April 2020 the standard payroll employment allowance (EA) of £4,000 is deemed to be
top-slice “De minimis State Aid”. There are limits on the amount of State Aid that can be received, if
those limits are breached the EA is reduced or withdrawn in full. The limit for the agriculture sector
is effectively €20,000.

Some farmers are receiving notification that the EA is not available because they receive an EU
subsidy, for example in the form of the Basic Payment. However, Pillar 1 direct payments (in the
form of the Basic Payment or Greening) delivered under the Common Agricultural Policy (CAP) are
not considered to be State Aid because EU law establishes the eligibility criteria. Whilst the
payments received in 2020 will come from the UK rather than the EU, the scheme criteria are
exactly the same so it would appear that the previous exemptions will apply.

Only State Aid provided by the UK from its own national funds would be deemed to be State Aid
along with other payments made as part of the Rural Development Programme (RDP) and not
exempted by Article 42 of the Treaty on the Functioning of the European Union (TFEU).

On 6th April the EU agreed that the £50bn coronavirus support package being implemented within
the UK is also legitimate State Aid.

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Tim Evans BSc FCA CTA
Chartered Accountant
Chartered Tax Adviser

Editor’s note: on 14 April DEFRA specifically confirmed to the group that:

“HMRC decided to obtain state aid clearance for the employment allowance using de minimis.
Each beneficiary has an agricultural de minimis allowance of 20,000 euros over a 3 year rolling
period. It is also useful to note that any funding you receive under the following Defra schemes,
however, does not count towards your agricultural de minimis state aid:

> Water environment grant
> Basic payment scheme
> Countryside stewardship
> Countryside productivity
> RDP LEADER grants

(and on the coronavirus support package…you will be entitled to both 20,000 Euros worth of de
minimis aid and 100,000 of direct grants under the agricultural part of the TF”)

SMALL BUSINESS RATING RELIEF GRANT – WILL SOME CLIENTS
MISS OUT?
In the interests of acting quickly to push out support to small businesses via an existing network,
one of the elements of the Covid-19 support package is a £10,000 small business grant. This is
available for businesses which are eligible for small business rating relief (SBRR), with the
exclusion of private premises (such as stables, moorings, beach huts etc.), car parks and parking
spaces. The payments should be made automatically, and government advice is that “if you are
eligible, your local authority will be in touch with you to arrange payment.” Most clients will have
received letters or emails early in April.

There is, however, a practical difficulty. Almost by definition the local authority will not have bank
details for the ratepayer. Accordingly, each local authority has needed to set up its own software
for information gathering. Most are starting the process with a simple eligibility checker, but others
seem to have unilaterally decided that certain properties may not be occupied by a business, and
blocked access to the payment process unless the ratepayer enters into email correspondence
with the authority. Some on-farm solar PV arrays have certainly been caught by this glitch, but
there could be other enterprises such as commercial liveries which are also affected.

In some cases, problems have arisen since the blocking process which has also disabled the
emails or letters which should have been sent out early in April. This means that unless a ratepayer
proactively goes through the local authority website and argues their entitlement, they will not even
know that they have an entitlement, or indeed may even believe that they are NOT eligible for the
grant. This may well be wrong and is almost certainly not what government intended.

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Most clients will already have received their guidance letter, been through the registration, and
received their payments, but some may still be in blissful ignorance, or waiting for a letter which will
not arrive. Where we know that a client may be eligible for this grant, a phone call to ensure that it
has been paid may not come amiss.

THE VALUE OF DEVELOPMENT LAND
We have probably all had clients who, after consulting that impeccable source, “the man in the
pub”, have concluded that a transfer of land to a connected party will save significant amounts of
CGT or IHT if it is made before planning permission is granted. In some cases the advice that
“hope value” will need to be considered in valuing the relevant assets comes as something of a
shock.

The case of Foster -v- R & C Commissioners which came for the First Tier Tribunal last autumn is
a clear example of how valuations in such cases will be treated by the Valuation Office Agency
(VOA) and illustrates not only that hope value is relevant, but that the valuation should be treated
on a “top down” basis, assessing the value of a site with the assumption that it has full permission
and that road access can be acquired, and then discounting backwards to reflect the risks that
these valuation enhancements may not be easily available.

The facts in this probate case were that 6.39 acres of land were valued by the executors at
£191,700 based on amenity value plus a premium for “hope”. The land did not have road access
and was outside the local development plan, but the VOA disputed the value and took the
approach that the land should be valued as if these issues did not exist, but then to discount the
value from the “top down”, recognising that a willing buyer would form an assessment of the
likelihood of being able to surmount the problems and would discount the value so as to reflect the
risks. The VOA approach meant that they determined a value of £850,000, assuming space for 50
houses, but discounting by 70% to reflect the inherent problems of the site and the possibility that
they might not be overcome because of the uncertainty.

In settling the taxpayer’s appeal, the tribunal concluded that, in the particular circumstances of the
case (as regards timing, local planning issues and the history of nearby sites) a willing buyer would
exist and would be prepared to buy the site with the attendant risks. In the absence of direct
comparables, the “top down” approach was the correct one to take. The only consolation for the
taxpayer was that the FTT disagreed with the VOA on the detail of the calculations, finding that a
45 plot development was more realistic and also that an 80% discount would be more appropriate.
Restating the value on this basis reduced the VOA figure from £850,000 to £590,000 – still some
way above the taxpayer’s estimate of £191,700.

The conclusions which can be drawn from this case are threefold – firstly, where a site needs
enhancement to secure a planning uplift, it will be valued on a “top down” basis, even if the
taxpayer has no intention to develop. Secondly, the VOA will argue the point for amounts which, in
some eyes, could be seen as relatively modest (the tax at stake here ending up at about £160,000)
and thirdly, of course, that once again the man in the pub is just plain wrong, but the adviser can
illustrate that with a relatively straightforward decided case.

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David Missen

DEATH ON THE FARM
The joy of self-isolation box sets

In reading the title you might think this is just another inheritance tax (IHT) planning article but the
death here is referring to murders (or potential murders!).

Televised commentary on farm murders have come through the recent “White House Farm”
murders and the fictional Welsh farm dispute of “15 days” with a number of murders. Perhaps with
everyone self-isolating at home there has been increased watching of such murder mysteries…
Concentrating on the fictional Welsh drama, I confess it is impossible for me to not shout out legal
and tax points at the screen as the drama unfolds. Let’s consider some of the points of the story. At
this point it is worth mentioning a few Budget updates and coronavirus pandemic potential impacts.

Jewelry goes missing

Perhaps less dramatic than some of the other legal and tax points but I found myself questioning
“why didn’t the executor secure the farmhouse/assets?” Perhaps that is answered in part over the
confusion over where the Will was located and what was the valid Will. The question I possibly
shouted at the drama was why didn’t the mother make it clear to her family where the Will was
located and who was executor? Perhaps the answer to that is when it transpires that the mother is
leaving the farm to her husband’s brother and not any of her children. The “uncle” in question was
originally disinherited by her father-in-law.

Validity of the Will

When it transpires that the brother-in-law has used his solicitor to draft his sister-in-law’s Will so he
is beneficiary and the children are questioning validity, I obviously shouted: “Obtain a Larke v
Nugus statement ASAP”, but possibly some of the dramatic emphasis in the storyline is lost…

The question of did the mother receive any tax planning or succession planning advice would have
possibly been dull. Finding out why and how everything changes in a professionally structured way
whilst taking calm independent legal advice by the siblings would have possibly spoilt the dark,
dramatic mood.

Likewise, when the eldest son who thought he was the beneficiary, shouts at his uncle (who turns
out to be a current Will beneficiary) “get off my land”, at an early stage I found myself shouting back
“obtain legal clarity first” and “check the uncle’s legal rights to occupancy”. The tax adviser’s role is
key in these situations as a complex case such as this needs tax planning and discussions prior to
the “bombshells” which could have helped reduce the number of murders – yes “tax planning and
legal clarity helps save lives”! Admittedly it also reduces the dramatic content…

Eldest son’s development plans

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As part of the spellbinding storyline was the eldest son’s desire to take over all the farmland and
sell for development and possibly not include any of his siblings, apparently a deal was close. At
this point I am obviously stating loudly that all the siblings need independent tax and legal advice.
Consideration as to qualification for Entrepreneurs’ Relief (ER) or Rollover Relief for Capital Gains
Tax (CGT) would be a key issue. Please note that in the Budget the lifetime limit for ER has
reduced from £10 million to £1 million which must be factored in and possibly highlights the future
strength of the “rollover buyer” when we hopefully “get to the other side”. As the probate value
would be the base cost for the CGT, had the eldest son or all the siblings achieved the sale the
importance of a quality probate valuation with hope value being taken into account per Foster
(Foster v R&C Commrs UKUT0251 (LC)) goes through the mind, and I am genuinely hoping there
is good tax advice, not all efforts being focused on trying to identify the murderer.

Father’s promises and concerns

It can be argued that at the root of the mother’s decision to change her Will to her brother-in-law
was that he was the father of the youngest child and the husband (the owner of the land) was
aware of this. Why then did he pass the ownership of the farm to his wife? A new Will with a trust of
the assets that qualified for Business Property Relief (BPR) and Agricultural Property Relief (APR)
for inheritance tax to his children could have been considered for example. It is good to note that
both APR and BPR survived the 2020 Budget despite speculation to the contrary. If his brother did
murder him and did inherit everything, Will validity would again be a question.

It might seem that murders and mental torture could have been avoided with well thought through
careful and positive legal and tax advice to protect all parties, but I accept it would have totally
spoilt the drama…

Positive action points to destroy a storyline

•      The uncle taking proper clear legal advice at the time he was originally inherited.

•      The father taking proper legal advice for his Will knowing his wife was unfaithful and protect
       his children in a tax efficient way.

•      Once the father was dead (murdered) the legal and tax arrangement for his brother farming
       the land being made clear and tax efficient.

•      The eldest son’s plans to “land grab and develop” being given cautious legal and tax
       considerations accepting that the “long-term sharing” strategy could be more beneficial for all
       parties than “smash, grab and develop”.

With the property market in lockdown and possibly a few more farm murder mystery box
sets/”catch up” TV being accessed by the Farming & Rural Business Community, I hope the article
is useful for when everyone is relaxing and trying to escape tax.

Supplied by Julie Butler F.C.A. Butler & Co, Bennett House, The Dean, Alresford,
Hampshire, SO24 9BH. Tel: 01962 735544. Email: j.butler@butler-co.co.uk, Website:
www.butler-co.co.uk

Julie Butler F.C.A. is the author of Tax Planning for Farm and Land Diversification

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(Bloomsbury Professional), Equine Tax Planning ISBN: 0406966540, Butler’s Equine Tax
Planning (2nd Edition) (Law Brief Publishing) and Stanley: Taxation of Farmers and
Landowners (LexisNexis), and editor of Farm Tax Brief.

1 April 2020

ALL CHANGE FOR LANDLORD AND TENANT – BUT NOT YET
Readers will recall that a consultation paper was issued last April regarding the legislation
governing agricultural tenancies. In the light of poor productivity growth in UK agriculture, which
has lagged behind that of our competitors for decades, the paper called for legislation to
encourage older and less efficient farmers to make way for younger and more enthusiastic
successors. Proposed changes have now been added on to the Agriculture Bill and referenced in
the Budget. On 18th March a summary of the consultation responses and proposed legislative
changes was also published.

One of the key proposals in the consultation was that 1986 Act tenancies were to become
assignable, subject to a 25 year term and a pre-emption right for the landlord. There were
considerable concerns on this issue, with some feeling that such a move would lead to a reduction
in the area of land available to rent, with landlords preferring to buy out the tenant and take land
back in hand rather than assenting to the assignment. On behalf of the ICAW the committee
drafted a response to the consultation expressing reservations on that point. Other respondees
contributed in similar vein, since that suggestion has not made it to the Agriculture Bill, although it
will no doubt be the subject of continuing discussion within the Tenancy Reform Industry Group.

Other changes which are to be implemented will be more generally welcomed. The Bill contains
clauses encouraging retirement by removing the minimum age at which a retirement succession
claim can be made and possibly removing succession rights where tenants are well past retirement
age (with corresponding amendments to the rules on council farms), removes restrictive clauses
which can inhibit diversification or expansion on the part of the tenant, makes changes to the rules
on arbitration and, perhaps most significantly, removes the “commercial unit” test which can block
a succession where a prospective tenant has a commercial unit elsewhere.

Surprisingly, one of the suggestions in the consultation which might have appeared noncontentious
has also been left out of the Bill. It was expected that the rules defining which family members
might be eligible for succession would be expanded to include nephews, nieces, grandchildren and
cohabitees, reflecting more general changes in society in recent years. This has also been omitted
from the Bill and will doubtless also be subject to further discussion within the industry in future.

Whilst the watered down reform will be disappointing for many (the TFA still believe further reform
is needed) it is possible that it will maintain balance in the relationship between landlord and
tenant. We had expressed concern that the original proposals might have had unintended
consequences, possibly even reducing the size of the tenanted sector as landlords chose to take
land back in hand, rather than risk seeing it let to an outsider for the next twenty five years, even if
that means buying out the tenant. Having regained possession, it also seems unlikely that a
landlord would risk re-letting, not knowing what further problems a different government might
make in this area, when he could simply take it back in hand or farm it with contractors (and of
course enjoy the fiscal advantages of farming in hand).

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David Missen

IT’S DIFFERENT IN SCOTLAND – PART 4: AGRICULTURAL SUPPORT
SYSTEM

Working with agricultural clients on both sides of the Scottish Border brings with it knowledge of the
agricultural support systems available to English and Scottish farmers.

Under the current CAP framework, the UK administrations have increasingly different approaches
in how they deliver agricultural and rural support. For example, payment rates per hectare under
the Basic Payment Scheme (BPS) vary significantly and the Scottish government still provides
some coupled support payments.

There are also differences in how schemes are administered. For example, under European
Commission rules, both countries must make the BPS payment between 1 December of the
scheme year and 30 June the following year. However, in Scotland there is currently a National
Basic Payment Support Scheme which has been in place since the 2015 scheme year. In 2019,
this scheme allowed businesses to receive a loan of 95% of their anticipated BPS and Greening
payment entitlement in October 2019 – up to the scheme limit of €150,000. In contrast, English
claimants must wait (some longer than others!) for their payment which will arrive at some point
during the seven month payment window.

When you look into the reasons for the differences, you begin to understand some of the
challenges facing Scottish agriculture when compared to the rest of the UK. Figures provided by
the SRUC in 2019 indicate that only 9% of Scottish farmland can be used for cropping, 21% for
grassland and 59% for rough grazing. The remaining 11% is used for ‘other’ of which forestry will
be a significant proportion. In contrast, 44% of English land can be used for cropping, 41% for
grassland, 9% for rough grazing and 6% for other. Interestingly, rough grazing accounts for 24% of
Welsh farmland and 16% of Northern Irish farmland. The significant area of rough grazing in
Scotland has contributed to the differences between the Scottish and English agricultural support
schemes over the years.

It is also interesting to note that over 85% of Scottish Farmland is classed as being Less Favoured
Areas (LFA) compared to 17% in England. This classification suggests that much of Scotland’s
farmland is most suited to the grazing of suckler beef cows and sheep. This has resulted in
Scotland maintaining coupled support for beef cattle and sheep unlike England and indeed the
other UK countries. Examples of such schemes are the Scottish Suckler Beef Support Scheme
(Mainland and Islands) which gives direct support to specialist beef producers, and the Scottish
Upland Sheep Support Scheme which provides additional support to sheep producers who farm in
Scotland's rough grazing areas.

There are also features of rural Scotland for which there is no equivalent in England. For example,
crofting which is specific to the Highlands and Islands. This has resulted in specific schemes in
Scotland, including the Crofting Agricultural Grant Scheme which provides grants to crofters to
make improvements to their crofts and the Croft House Grant which provides grants to crofters to
improve and maintain the standards of crofter housing.

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Following Brexit on 31 January 2020, it will be interesting to see how the future agricultural support
systems of England and Scotland develop. The UK government has outlined its intention to phase
out the Basic Payment Scheme by 2028 in favour of a new Environmental Land Management
System (ELMS). From 2022, it is envisaged that payments will be delinked from agricultural
activity. Based on historical and current support in Scotland, it may prove difficult for the Scottish
government to stop providing some support in the form of direct payments.

Roseanne Bennett
Partner, Greaves West & Ayre

IMPACTS OF COVID-19 ON FARMING

Farmers and their suppliers are amidst a very busy spring programme as drilling and planting hits
top gear. The Coronavirus (COVID-19) pandemic is having a wide-ranging impact, even affecting
planting decisions this year. It is also causing concerns with supply chain slowdowns, farmers’
health and the wellbeing of their farming workforce. Keeping the workplace free of COVID-19 is of
utmost importance to those industries that cannot work remotely and agriculture is no exception.

The UK’s food security and supply needs from our UK farming and livestock activities is in sharp
focus. As the situation rapidly changes in the face of the virus and its resulting health threats and
control measures, our agricultural team have looked at the likely impact on the industry.

Supply chains slowdowns

Arable and Livestock alike have already experienced supply chain glitches. Whether it has been
fuel delivery delays due to tanker driver shortages or non-collection of milk due to processors being
short staffed the early indications are that farming is in for a bumpy ride. The entire farming sector
is conscious of how finite their workforce is and without them, what the impact would be upon the
farming business and the rural economy. Further logistics are being disrupted as efforts are put in
place to slow the spread of the virus. We have seen with some products, panic buying has been
creating additional demand. We could yet see issues with farm product delivery and pickup as
workers in the ancillary sector fall ill or are tied up with family responsibilities at home. These same
concerns may affect the mills, abattoirs, markets, factories, dairies and processors. Slowdowns
could also affect delivery of fertilizer, fuel and other input movement and availability as we head
further in to spring.

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Farmers’ health & a healthy workforce

Farmers are a relatively older population compared to the general UK workforce. COVID-19 is
proving more dangerous to those aged 70 years and above.2 Whilst the rural nature of the industry
makes the disease less prevalent it does still mean it is essential to keep protective measures in
place to protect the farming industry workforce. Only by controlling the spread of the illness can the
impact on agriculture be mitigated. The ongoing welfare of the farm workforce and those in the
integrated networks is critical for our ongoing food supply.

Farmers (despite the difficult environment in which they work) will need to follow government
health official advice:

       washing hands regularly,
       limiting non-essential travel,
       maintaining social distancing.

Markets and farm prices

The normal purchasing habits of consumers as well as the closure of fast food outlets, restaurants,
pubs and hotels has changed the supply chain. Adding in the human factor as people intrinsic to
the supply chains performance fall ill, means that many routines have fallen away. Milk collections
become sporadic, fish and chip shops no longer need potatoes and the buyers for certain types of
meat that would have gone into the catering trade have dried up. This is having an impact upon
markets with unpredictability causing price volatility in an already sensitive market place. Budgeting
for such substantial change following the weather events of the last 6 months is lending ever
greater pressure to farm accounts.

Worker safety and Personal Protective Equipment (PPE)

As with all sectors of the economy, finding suitable sanitisers and PPE is proving tricky. PPE and
other protective equipment is vital for operating a farm safely. Keeping workers and animals
healthy is fundamental to public health ongoing. However, due to current demands by the
healthcare industry, these supplies are highly limited including protective gloves which have now
become commonplace in dairy operations as a means to improve milk quality and protect the
health of animals and people.

We want to keep the farming community informed on the coronavirus and its impact on the UK
farming industry across all sectors. It is important to us that your insurances are arranged correctly,
tailored around your own needs and in doing so give you peace of mind.

To find out more on how we can be if assistance please contact our farming specialists.

Sources:
https://www.gov.uk/coronavirus (1)
https://www.gov.uk/government/publications/covid-19-guidance-on-social-distancing-and-
forvulnerable-people/guidance-on-social-distancing-for-everyone-in-the-uk-and-protecting-
olderpeople-and-vulnerable-adults (2)

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DATES FOR YOUR DIARY
O

On-Demand The new normal – talk professionally online
We are having to talk online, but its easy to get it wrong when at home.
https://event.on24.com/wcc/r/2271685/61759556923CA994ABE47D3BDC54982B

On-Demand Brexit and lockdown in the EU
What Brexit, and the lockdown, means for UK taxpayers around the EU.
https://event.on24.com/wcc/r/2233183/17DB47246C6B10A3C93FDAB119D8F321

26 May Data analytics live Q&A: Data prep 101
Pose your questions live to our subject matter expert. https://events.icaew.com/pd/15508/data-
analytics-live-qa-data-prep-101

Farming & Rural Business Community subscribers can access further information at:
http://www.icaew.com/farminggroup

T +44 (0)1908 248 250
E communities@icaew.com

Views expressed in this newsletter are those of the author and may not represent
ICAEW policy. No responsibility for loss occasioned to any person acting or refraining
from action as a result of any material in this publication can be accepted by the
publisher or authors.

© ICAEW 2020. All rights reserved.

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