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HMRC internal manual

Business Income Manual

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HM Revenue & Customs
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Measuring the profits (particular trades): land transactions: contents

Chap 3 Part 13 Income Tax Act 2007, Part 18 Corporation Tax Act 2010

This guidance describes what the transactions in land anti-avoidance legislation seeks to achieve, outlines the provisions and provides examples of where they may be applied.

Any case where an Officer considers that the anti-avoidance provisions apply must be submitted to CTISA (Technical) before the matter is raised with the taxpayer or agent.

The full contents of this chapter are as follows:

  1. BIM60305
    Overview
  2. BIM60307
    Straightforward transactions of purchase and sale
  3. BIM60310
    Conditions
  4. BIM60315
    Conditions: territorial scope
  5. BIM60320
    Conditions: motive test
  6. BIM60325
    Person obtaining the gain
  7. BIM60328
    Provider of value or opportunity
  8. BIM60330
    Right to recover the tax from another person
  9. BIM60333
    Computation
  10. BIM60335
    Period in which the gain is taxed
  11. BIM60337
    Transactions, arrangements, sales and realisations
  12. BIM60340
    Common situations
  13. BIM60345
    Common situations: Diversion schemes
  14. BIM60350
    Common situations: 'Slice of the action' contracts
  15. BIM60355
    Common situations: 'Slice of the action' contracts: Identification
  16. BIM60360
    Common situations: 'Slice of the action' contracts: Portion of charge may be exempt
  17. BIM60365
    Land developed for gain: Portion of charge may be exempt: Example
  18. BIM60370
    Exemptions: Profit chargeable as trading income
  19. BIM60375
    Exemptions: Principal private residence
  20. BIM60395
    Clearance applications: Overview
  21. BIM60400
    Clearance applications: conditions for application
  22. BIM60405
    Clearance applications: Reference to CTISA (Technical)
  23. BIM60410
    Clearance applications: Time limit
  24. BIM60415
    Clearance applications: Obtaining further information
  25. BIM60420
    Clearance applications: Acceptance
  26. BIM60425
    Clearance applications: Refusal
  27. BIM60430
    Clearance applications: Form of words to accept or refuse clearance
  28. BIM60435
    Clearance applications: Multiple applications in relation to the same transaction
  29. BIM60450
    Definitions: Land
  30. BIM60455
    Definitions: Property deriving its value from land
  31. BIM60460
    Definitions: Developed
  32. BIM60465
    Definitions: Disposal
  33. BIM60470
    Definitions: Gain of a capital nature
  34. BIM60475
    Definitions: Connected person
  35. BIM60480
    Definitions: Another person
  36. BIM60500
    Tax cases