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HMRC internal manual

Business Income Manual

HM Revenue & Customs
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Meaning of trade: badges of trade: method of finance

The method of financing should be examined. The purchaser of an asset may have to borrow money in circumstances that indicate that, from the first, he has to sell the asset to repay the loan. That is, the purchase is undertaken in the expectation that the asset will be paid for out of the proceeds of the sale.

For example, in Wisdom v Chamberlain [1968] 45TC92 the taxpayer was held to be trading in relation to profits made from the purchase and sale of silver bullion. His normal occupation was not in that sort of activity. The purchase of the bullion was financed by loans at a high rate of interest in circumstances that made it clear that it was necessary to sell the asset in the short term, to repay the loan and eliminate the interest obligation.