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HMRC internal manual

Business Income Manual

Trade profits: who is chargeable?

S8 Income (Trading and Other Income) Act 2005

Income Tax on trade profits is chargeable, in general, on the persons receiving or entitled to the income. The person chargeable under this provision is usually obvious as the person who both receives and is entitled to the income. However, in some situations, the charge relies on the receipt aspect alone. There is specific guidance on these and other situations as follows:

Deceased persons TSEM7200 onwards
Trustees TSEM3010 onwards


Where the person carrying on the trade is not resident in the UK the tax charge can be made on the non-resident’s UK representative. There is detailed guidance on this treatment at INTM268000 onwards.