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HMRC internal manual

Business Income Manual

HM Revenue & Customs
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Farming in tax law: all farming to be treated as a trade

S9 Income Tax (Trading and Other Income) Act 2005, S36 Corporation Tax Act 2009

All farming (see BIM55051) should be treated as the carrying on of a trade, whether or not there is commercial motivation. For example people who breed horses as a hobby are usually treated as farming and are therefore carrying on a trade, even though general principles would not point to the existence of a trade. However, this does not mean that the activity will qualify for loss relief, see BIM85600.