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HMRC internal manual

Trusts, Settlements and Estates Manual

Ownership and income tax: Specific types of property: land and buildings - taxation of rental income

For the taxation of rental income from property held jointly by married couples or civil partners, see TSEM9800. Otherwise, the following applies.

Profits from UK and foreign land and buildings are treated for tax purposes as arising from a business (PIM1020). Under ITTOIA/S268, income tax is charged on the profits of a property business. Under ITTOIA/S271 the person liable for the income tax under S268 is the person receiving or entitled to the profits.

In the context of rental income, the ‘property’ from which the income derives may be the actual land or building itself or it may be a lease.