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HMRC internal manual

Business Income Manual

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

How value is derived or tracing value is set out in Section 356OM CTA 2010 and Section 517N ITA 2007.

The legislation explains how to determine the value of a property or right that derives from any other property or right.

Where it is necessary, value can be traced through companies, partnerships or trusts, and property should be attributed to shareholders, partners and beneficiaries in a way that is consistent with the circumstances.

‘Partnership’ includes a non-UK entity which is of a similar nature to a UK partnership.

‘Trust’ includes arrangements that have effect under the law of a country outside the UK, and are a vehicle in which persons acting in a fiduciary capacity hold and administer property on behalf of beneficiaries.