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HMRC internal manual

Business Income Manual

Trade profits: statute - supplementary charging provisions - mines, quarries and other concerns

S12 Income (Trading and Other Income) Act 2005; S39 Corporation Tax Act 2009

Profits or gains arising out of land for specified concerns are calculated as if the concern were a trade. Any profits arising out of the land are charged to Income Tax or Corporation Tax as trading income.

The concerns

  1. mines and quarries, including gravel pits, sand pits and brickfields; see BIM62000 onwards
  2. ironworks, gasworks, salt springs or works, alum mines or works and waterworks and streams of water
  3. canals, inland navigation, docks, and drains or levels
  4. rights of fishing
  5. rights of markets and fairs, tolls, bridges and ferries
  6. railways and other kinds of way
  7. other concerns of the same kind as any of the concerns in (b) to (e) above.

BIM60201 gives guidance on the circumstances in which a concern is within the charge on trading income.