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HMRC internal manual

Stamp Duty Land Tax Manual

Scope: when is Stamp Duty Land Tax (SDLT) chargeable: higher rate charge for acquisitions of residential property by certain non-natural persons FA03/S55/SCH4A: meaning of ‘carried on a commercial basis with a view to the realisation of profits’

The trade must be carried on a commercial basis and with a view to the realisation of profits.

If a trade is, or is to be, carried on in such a way as to try and discourage people taking advantage of the opportunity to use the dwelling (for example, by making it practically difficult or available only on days or at times that are unlikely to be used) this will not be carried on a ‘commercial basis’.

It should be noted that only the particular trade must be carried on in this manner. If a historic house is open to the public or available as a wedding venue, it is that activity which must be carried on commercially and with a profit seeking motive. The relief is intended to be available where the owner is operating a trade to subsidise the running costs of a historic house.