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HMRC internal manual

Employment Income Manual

HM Revenue & Customs
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Tax treatment of insurance agents: Trading Income cases

Statement of Practice SP4/97 (see EIM64605) also coverscases where liability arises under the Trading Income rules . The Trading Income part ofthe Statement is reproduced in the Inspectors’ Manual at BIM40655. Broadly, whencommission is received on a regular basis or from a genuinely casual arrangement it may betreated as Trading Income. See BIM40650 onwards and BIM80100 onwards. An unexpected,wholly gratuitous, non-business receipt will not be chargeable to tax as Trading Income.