Milk quotas were introduced by the Dairy Produce Quota Regulations 1984 (SI 1984/1047), allowing producers to sell dairy produce up to their quota without attracting a supplementary levy (see ¶270-800). The concept is one of EC law, and does not fit easily into the UK concept of interests in land. While the quota is allocated in respect of a particular holding of land, and the quota is normally transferred with the land to which it is attached, HMRC have always been of the view that the land and the quota are separate assets (see CG77820). Indeed, milk and potato quotas constitute a specific class of assets qualifying for roll-over relief (see ¶571-100).

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