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HMRC internal manual

Business Income Manual

HM Revenue & Customs
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Meaning of trade: badges of trade: quantity purchased

The quantity of a commodity, or other asset, purchased can also be a factor.

In CIR v Fraser [1942] 24TC498 (see BIM20230) the court commented that the commodity in question, whisky, had been bought in quantities which were far in excess of anything which could be used by the individual personally, or his family and friends. This weighed in favour of the trading view.

The same point arose in Rutledge v CIR [1929] 14TC490 where the transaction involved the purchase and sale of one million rolls of toilet paper.

Purchases in excess of a normal non-trade use may be a factor in the case of any of the asset types in BIM20245, but usually other badges of trade must be present to establish the existence of a trade or venture in the nature of trade.