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HMRC internal manual

Business Income Manual

Amounts treated as profits of a trade of dealing in UK land: Person realising a profit or gain

The legislation applies where the person, or persons, who obtain the profit or gain meets one of the conditions in Section 356OB(2) CTA 2010 or Section 517B(2) ITA 2007.

The person must be either:

  • The person acquiring, holding or developing the land.
  • A person who is associated with that person, at a relevant time or
  • A person who is party to, or concerned in an arrangement.


An arrangement is covered by Section 356OB(3) CTA 2010 or Section 517B(3) ITA 2007, if it is carried out with respect to all or part of the land, and enables a profit or gain to be realised by an indirect method or a series of transactions.


Any number of transactions can be a single arrangement where they have a common purpose or there is sufficient evidence of a common purpose.


The definition of chargeable person is at BIM60820.