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HMRC internal manual

Business Income Manual

From
HM Revenue & Customs
Updated
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Measuring the profits (particular trades): land: trading transactions: question of fact

Whether a specific transaction is or is not a trading transaction is a question of applying the rules, or the badges of trade, to the detailed facts of the particular case. The ultimate arbiter of any dispute is, if necessary, the Tribunal. A good example is Marson v Morton and Others [1986] 59TC381.