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HMRC internal manual

Business Income Manual

Underwriting of shares: taxation of profits

Any profits from underwriting issues of shares, including those of a casual nature, are liable to tax: Lyons v Cowcher [1926] 10TC438.

A financial concern within the charge to tax on trade profits should include any profits from underwriting in the computation of its trade profits.

If any other person acts as underwriter on a number of occasions, they may be regarded as carrying on a trade of underwriter. See BIM20235 for further guidance on this point.

In any other case, the profits should be charged as miscellaneous income (see BIM67005).