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HMRC internal manual

Business Income Manual

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Land transactions: Definitions: Gain of a capital nature

S772 Income Tax Act 2007, S833 Corporation Tax Act 2010

A gain is potentially within the transactions in land rules if it does not otherwise fall to be included in any calculation of income for either Income Tax or Corporation Tax purposes (see BIM60305).

UK capital gains fall within this definition, see Page v Lowther [1983] 57 TC 199, as well as any gains or profits realised by non-residents, see Sugarwhite v Budd [1988] 60 TC 679.