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HMRC internal manual

Business Income Manual

Specific receipts: unclaimed balances: contents

This part of the guidance describes the treatment of issues that arise following the recognition in profit and loss accounts of sums that many traders consider to be in the nature of ‘windfalls’.

As the sums may be unexpected or unpredictable in nature, traders sometimes claim that they are not taxable, arguing that they do not arise from the trade. However, an element of the unexpected or unpredictable in a receipt does not mean that it is not a trading receipt or not taxable. This is especially so where such sums are a common feature of the trade.

The following related issues are covered elsewhere:

  • voluntary payments and whether they are trade receipts (see BIM41810)
  • the treatment of unclaimed balances in the accounts and computations of financial institutions (see CFM71030)
  • the treatment of corporate debt under the loan relationship regime (see CFM30000)

The guidance is arranged as follows: