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HMRC internal manual

Venture Capital Schemes Manual

From
HM Revenue & Customs
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Excluded activities: dealing in land, in commodities or futures or in shares, securities or other financial instruments

ITA07/S192(1)(a); ITA07/S303(1)(a)

These sections exclude dealing in land, in commodities or futures or in shares, securities or other financial instruments.

‘Dealing in land’ includes cases where steps are taken, before selling the land, to make it more attractive to a purchaser. Such steps might include the refurbishment of existing buildings.

The dictionary meanings of ‘commodities’ and ‘goods’ are rather similar, but it can be inferred from the use of the words in adjacent paragraphs that they are intended to have distinct meanings here. The distinction is most easily conveyed by means of an example; sugar is a commodity, but a bag of sugar is goods.

Dealing in commodities covers any dealing done on a commodities market. Inspectors should not contend that dealing done in any other way comes under this heading without first consulting CTIAA (CT Structure, Incentives & Reliefs team). A manufacturing trade in which a ‘commodity’ is used in the manufacturing process is not regarded as disqualified merely because the company carrying it on buys in the commodity markets and has dealings in the futures markets to even out price fluctuations.