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HMRC internal manual

Business Income Manual

HM Revenue & Customs
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Meaning of trade: mutual trading and members clubs: golf clubs: introduction

There are two broad categories of golf club - members’ clubs and proprietary clubs.

As explained in BIM24200, the typical members’ club does not carry on a trade with its members and so the issue of mutual trading does not arise. Where a members’ club trades with non-members, the profits from that activity do not derive from a mutual trade; the club is taxed on those profits in just the same manner any other trader.

Where a members’ golf club trades with non-members the principal concern is to determine the allocation of expenses deductible from the trading income to enable a balance of profits to be struck. This issue is discussed in detail at BIM24360.

A proprietary golf club does not carry on a mutual trade; the proprietor simply carries on the business so the trading profits are taxable as trading income in the normal way.