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HMRC internal manual

Business Income Manual

HM Revenue & Customs
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Measuring the profits (particular trades): land: trading transactions: land acquired by inheritance or gift

Where land is acquired by inheritance or gift, its subsequent disposal will not ordinarily be chargeable as trading income: Hudson’s Bay Company v Stevens [1909] TC424 and Williams v Davies [1945] 26TC371.

A possible exception to this general rule is where, following acquisition, the recipient decides to use the property to start trading in land. This would be the commencement of a supervening trade (see BIM60060).