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HMRC internal manual

Business Income Manual

Profits from a trade of dealing in or developing UK land: Disposals of land: profits treated as trading profits

Where the conditions in Section 356OB CTA 2010 or Section 517B ITA 2007 have been met, the profits are treated as trading profits by Section 356OC CTA 2009 or Section 517C ITA 2007.


The amounts should be treated for corporation tax or income tax purposes as profits of a trade carried on by the chargeable company or person.


If the company or person are not UK resident then the company or individual’s trade is that of dealing in or developing UK land.

Any profits or gains which have already been brought into account, for income tax or corporation tax purposes, by another Section of legislation should not be included.

The profits should be treated as arising in the accounting period in which the profit or gain is realised.