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HMRC internal manual

Business Income Manual

Definitions: Realising a gain

‘Realising a gain’ is set out in Section 356OT CTA 2010 and Section 517T ITA 2007. The meaning of ‘realising a gain’ is extended to include realising a gain for another person.



Person A (“A”) and person B (“B”) are related parties.

If, by a premature sale, A directly or indirectly transmits the opportunity of realising a profit or gain to another B, then A realises B’s profit or gain for B.