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HMRC internal manual

Business Income Manual

Meaning of trade: badges of trade: assets with no income yield or ‘pride of possession’

There are, of course, assets where the limitation implicit in BIM20255 cannot apply. Some commodities or other assets are of such a nature that in addition to yielding no income they produce no aesthetic enjoyment, no ‘pride of possession’, and are of a sort that is normally dealt in by way of trade.

In Wisdom v Chamberlain [1968] 45TC92 profits were made from the purchase and sale of silver bullion by an individual whose normal occupation had nothing to do with that type of activity. In addition to producing no income, being held short-term and financed by loans at a high rate of interest, the fact that the bullion, while it lay in the vaults, was otherwise useless, was a factor that influenced the courts to agree with the Commissioners. That is, that the transactions were of a trading nature.