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The grant of a tenancy of agricultural property in the UK, for use for agricultural purposes is not a transfer of value by the grantor if he makes it for full consideration in money or money's worth¹. Grants before 6 April 2024 would also not be treated as a transfer of value if the agricultural property was situated in the Channel Islands or the Isle of Man².

It seems most unlikely that 'grant' in this context has its strict meaning of a grant of a legal estate (as opposed to a tenancy agreement operating only in equity). However, the most common type of agricultural tenancy, a market rent tenancy from year to year, is almost certainly within the Law of Property Act 1925, s 54(2) and capable of being a grant in the strict sense even though created informally and not by deed³.

It should also be noted that IHTA 1984, s 16 will not necessarily prevent the grant of an agricultural tenancy from being taken into account as part