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.