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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Substantial shareholdings exemption: interpretation - trade


Paragraph 27 Schedule 7AC TCGA 1992 explains what is meant for the purposes of the substantial shareholdings exemption legislation by ‘trade’. It means anything that

  • is a trade, profession or vocation within the meaning of the Income Tax Acts (including activities such as farming that are treated as a trade by section 53 ICTA 1988), provided
  • it is conducted on a commercial basis and with a view to the realisation of profits.

In addition a Schedule A business that consists of the commercial letting of furnished holiday accommodation in the United Kingdom is treated as a trade for the purposes of Schedule 7AC (section 241 TCGA 1992 as amended by paragraph 3 Schedule 8 Finance Act 2002 - see CG53260).