IHTA84/S121 (2) refers back to the replacement provisions (
IHTM24132) in IHTA84/S121 (1)(c). It
provides that, except where the replacement concerned resulted from
the formation, alteration or dissolution of a partnership, the
agricultural relief shall not exceed what it would have been had
the replacement(s) not been made. Your approach to S121(2) should
be similar to that to replacement property (
IHTM24112) generally.
Similarly, if the earlier transfer arose from a disposition
which was part bounty and part for consideration, for example, a
sale at less than the full value, IHTA84/S121 (3) provides that the
relief on the second transfer is restricted to the proportion of
the value corresponding to that which the element of gift bore to
the total value involved in the first transferor's disposition.
