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HMRC internal manual

Business Income Manual

HM Revenue & Customs
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Trade profits: statute - supplementary charging provisions

There are activities which produce income from the use of land or which arises out of land. These activities may or may not be trades within the normal meaning of that word for tax purposes. The question is put beyond doubt by specific provisions in the Income (Trading and Other Income) Act 2005 and Corporation Tax Act 2009 for the following activities:

Farming and marketing gardening (see BIM15060).

Occupation of land managed on commercial basis (see BIM15065).

Profits or gains arising out of land in the case of mines, quarries and other specified concerns (see BIM15070).