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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: acquisition and disposal of superior interest

Where a tenant occupying land buys and immediately resells a superior interest in that land, it may be possible to argue that the transaction amounts to an adventure in the nature of trade. Such an interest will often be the landlord’s freehold.

This is so whether the tenant is a residential, commercial, industrial or agricultural tenant.