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No idea. I make a point of not doing anything tax-related, mostly because I don't want to spend all my time helping rich people pay less tax.
My working assumption is that you'll get schtupped up the backside for lots of tax unless you're a billionaire or a multinational company, in which case tax is optional. In this case I'd imagine you'd get taxed either on the value of the land (if the sites they're getting aren't part of the land they're selling) or the uplift in value as a result of the increased value of the land (if the sites they're getting is part of the land being sold). Either way, my guess is they'll get taxed on the value of the 'stuff' they're getting out of the deal whether it's cash or not. But like I said, I don't do tax stuff.
Asking for a friend, @danstuff might know? Selling farmland, will not receive cash but fully developed sites you can build a house on. Tax?