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HMRC internal manual

Business Income Manual

Profits from a trade of dealing in or developing UK land: Overview

All profits from a trade of dealing in or developing UK land are now specifically subject to tax in the UK.

The new rules have been brought in through amendments to Section 5 CTA 2009 and Section 6 ITTOIA 2005, repeal of Part 18 CTA 2010 and Chapter 3 Part 13 ITA 2007, and the introduction of Part 8ZB CTA 2010 and Part 9A ITA 2007.

The amendments to Section 5 CTA 2009 and Section 6 ITTOIA 2005 expand the scope of the UK legislation, to include dealing in and developing UK land regardless of the residence of the company or individual, or whether that company or individual is trading in the UK through a permanent establishment.

Section 5B CTA 2009 and Section 6B ITTOIA 2005 set out what is meant by a trade of dealing in or developing UK land.  

Part 8ZB CTA 2010 and Part 9A ITA 2007 prescribe the treatment of certain transactions or arrangements that will form part of profits of a trade of dealing in or developing UK land.

The commencement and transitional provisions set out the treatment of transactions in the period between Budget day (16 March 2016) and the introduction of the legislation on 5 July 2016; and of transactions that straddle 5 July 2016.