Despite section 103,
duty is chargeable on a transaction (a subsequent transaction ) that would
otherwise be an exempt family farm transaction if —
(a) duty
was not charged on an exempt family farm transaction (the first transaction );
and
(b)
liability to duty on the subsequent transaction arose —
(i)
within 5 years of the first transaction; and
(ii)
the transaction relates, in the opinion of the
Commissioner, to the same farming property that was the subject of the first
transaction.