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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: supervening trade: planning permission

The obtaining of planning permission prior to sale does not, in itself, characterise a transaction as a trading transaction: Taylor v Good [1974] 49TC277. It may, however, provide evidence of intention and thus add weight, in certain circumstances, to a trading argument.