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HMRC internal manual

Business Income Manual

Receipts: general: possible future repayment

It should be noted that the mere fact that income may, in certain later circumstances, have to be repaid, does not preclude its treatment as a trade receipt (Smart v Lincolnshire Sugar Co Ltd [1937] 20TC643).

Guidance specific to the treatment of commissions received by insurance brokers on ’indemnity terms’ is given at BIM40680.