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HMRC internal manual

Business Income Manual

Historic houses: separate activities

A house that is open to the public may offer visitors additional attractions, such as a safari park, or a garden centre for the sale of plants etc. It is necessary to consider whether the income these activities produce should be considered to be part of the house and garden enterprise, or whether the activity forms a separate trade. This will depend on the particular facts of each case. In Scales v George Thompson and Co Ltd [1927] 13TC83 Rowlatt J observed on page 86, `the real question is was there any inter-connection, any interlacing, any interdependence, any unity at all embracing those two businesses’.

Thus the sort of factors to consider are, whether the two activities are co-located or physically separated, the degree of joint promotion, and the similarity of the opening hours.