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HMRC internal manual

Business Income Manual

Profits from a trade of dealing in or developing UK land: Relevance of transactions and arrangements

The relevance of transactions, arrangements etc. is set out in Section 356ON CTA 2010 and Section 517O ITA 2007.

In order to determine whether there is a charge to tax in Section 356OC(1), 356OE(1) CTA 2010 or Section 517 C(1) or 517E(1) ITA 2007  you must consider any method (however indirect this might be) by which:

  • Any property or right over property is transferred or transmitted, or
  • The value of any property or right over property is enhanced or diminished.

 

This means that any occasion in which property is transferred or transmitted, or, the value of property is enhanced may be an occasion on which the transactions in UK land rules apply, resulting in a charge under Section 356OC(1), 356OE(1) CTA 2010 or Section 517 C(1) or 517E(1) ITA 2007.