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HMRC internal manual

Business Income Manual

Disposals of property deriving its value from land – profits treated as trading profits

Where the conditions are met, Section 356OE CTA 2010 and Section 517E ITA 2007 set out the profits that should be treated as trading profits.


The relevant amount should be treated as profits of a trade carried on by the chargeable company or person.  


If the chargeable company or person is non-UK resident, then their trade is dealing in or developing UK land.


The relevant amount should not be treated as a profit or gain for corporation tax or income tax  purposes under these provisions, if it would already be brought into account as income for corporation tax or income tax [under another piece of legislation].


The profits are treated as arising in the accounting period in which they are realised.