BIM51505 - Builders, property dealers & developers: background
When considering whether profits derived from the acquisition and disposal of property (with or without development) are chargeable to tax as income and, if so, under what category, you should consider:
Where the profits are not trade profits, liability to tax may in certain circumstances arise under the stand-alone charge for land transactions (see BIM60300 onwards). Where appropriate in a contentious case, alternative assessments should be made in respect of trade profits and the land transactions charge.
In cases in which the question of the valuation of land and buildings is material to the determination of trade profits, see the guidance at BIM51560 onwards.