Revenue Tax Briefing Issue 61, November 2005
Where a farm business, including payment entitlement, is sold to a person who intends to carry on the farming business, then the sale may be treated as the transfer of a business or part thereof, provided all the relevant conditions are met. If the sale fails to meet the necessary criteria then the sale of the payment entitlement will be taxable as described in either 6.2 or 6.4.