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HMRC internal manual

Business Income Manual

From
HM Revenue & Customs
Updated
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Transactions in land: Straightforward transactions of purchase and sale

The transactions in land anti-avoidance provision should not be used to catch straightforward transactions of purchase and sale of land that do not amount to a trade, or adventure in the nature of trade.

That is, these provisions are not an alternative tax treatment where the land is purchased by a UK resident person and sold to an unconnected person in a transaction that falls short of a trade. This is the case even if there has been some construction on, or development of, the land before sale.

For guidance on whether the transaction amounts to a trade and so the profit is chargeable to Income Tax or Corporation Tax as trading income (rather than falling within the transactions in land rules), see BIM60000.