Readers’ forum: Will losses prevent relief claim?

Since the late 1970s my client has farmed land (rearing and selling sheep). They registered for VAT and maintained a business bank account. The farming was initially lucrative but with time they would only manage a profit every five years or so. The profits and losses have always been reported to HMRC.

In 2018 my client was diagnosed with a serious illness and they sold all the farming equipment and their trading stock. Since 2018 they have let the land for the grazing of horses. The client remains responsible for the upkeep of the land maintenance of the fencing and day to day husbandry.

The profit from grazing has continued to be reported as income from farming and a white space disclosure made on the self-assessment tax return along the lines that the grazing is a continuation of the farming activity in line with...