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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: mutual associations: specific activities: NHS doctors’ co-operatives: essential pre-requisite

Is the co-operative trading?

Whether particular activities are conducted in such a way as to amount to a trade is essentially a question of fact. There is detailed guidance at BIM20050 onwards. At the margin the issue can call for fine judgement.

There are commercial deputising services that do carry on a trade and these can offer comparison.

At their most rudimentary, some co-operatives appear to have minimal organisation, providing little more than the administrative minimum to achieve reciprocal arrangements between the parties; somewhat like those found in ‘baby sitting circles’, at a price designed to do no more than cover costs. You will need to form a judgement as to whether the activities are conducted in such a way that a Tribunal would find them to amount to trading.