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Farmer & his wife wish to transfer a parcel of land – 7 acres which includes mobile home where son lives (pays rent to farmer) to son in lieu of his inheritance.

Valuation is approx £250k as there is established residential use (over 10 yrs) with the mobile home. The land is in agricultural use and would qualify for Agricultural Property Relief. The farmer wishes to make this transfer now so son can have mobile home and land now & use for security to borrow against & build log cabin. Land will continue in agricultural use. Would this attract CGT? (land originally purchased at approx £2k per acre with no mobile home so base price say £14k) Solicitor has suggested putting it into a discretionary trust with son as beneficiary with holdover relief. After a period of time, say 1 yr (although I believe time is min 3mth + day) then asset transferred out of trust to son with holdover relief being claimed again. If land & mobile home are not transferred now but wait until last death of farmer/wife then would no IT be due as covered by APR or if not then below IT threshold as rest of farm will get APR & v little other assets. The rest of the farm will be split between the 2 other children on last death of farmer/wife. Value of farm (farmhouse & land) £1m.

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