BIM60565 - Amounts treated as profits of a trade of dealing in UK land: Person realising a profit or gain

»Ê¹ÚÌåÓýapp legislation applies where the person, or persons, who obtain the profit or gain meets one of the conditions in Section 356OB(2) CTA 2010 or Section 517B(2) ITA 2007.

»Ê¹ÚÌåÓýapp person must be either:

  • »Ê¹ÚÌåÓýapp person acquiring, holding or developing the land.
  • A person who is associated with that person, at a relevant time or
  • A person who is party to, or concerned in an arrangement.

An arrangement is covered by Section 356OB(3) CTA 2010 or Section 517B(3) ITA 2007, if it is carried out with respect to all or part of the land, and enables a profit or gain to be realised by an indirect method or a series of transactions.

Any number of transactions can be a single arrangement where they have a common purpose or there is sufficient evidence of a common purpose.

»Ê¹ÚÌåÓýapp definition of chargeable person is at BIM60820.