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HMRC internal manual

Business Income Manual

Specific receipts: grants and subsidies: government, local authority and EU grants

The treatment for tax purposes of grants and subsidies from UK government departments, local authorities or funds under the auspices of the EU (for example, the European Regional Development Fund) follow normal principles.

EU grants to induce farmers to switch from dairy farming to beef production were held to be revenue receipts in White v G & M Davies [1979] 52TC597 and CIR v Biggar [1982] 56TC254. These and other farming grant cases are also considered in the guidance on farming at BIM55000 onwards.

Non trading activities

A grant or subsidy may also be received in relation to non-trading activities. In this situation, the grant or subsidy is not taxable income.

Business advisory centres such as Business Connect, Local Enterprise Companies, Local Authority Companies and Enterprise Agencies may be providing a service that is not a trade - see BIM58201. A grant received for this activity would not be taxable.