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HMRC internal manual

Business Income Manual

HM Revenue & Customs
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Measuring the profits (particular trades): Mineral extraction: Profits of mining and quarrying deemed trade profits

S12 Income Tax (Trade and Other Income) Act 2005, S39 Corporation Tax Act 2009

The profits arising out of land used for mines, quarries (including gravel pits, sand pits and brickfields) are taxed as if the concern were a trade.

This rule does not, however, impose a charge to tax on a non-UK resident in the case of a concern outside the UK.

Businesses carrying on a mineral extraction trade are not eligible to use the cash basis (see BIM70000 onwards)