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

From HM Revenue & Customs · Business Income Manual

The legislation applies where the person, or persons, who obtain the profit or gain meets one of the conditions in or .

The person must be either:

  • The person acquiring, holding or developing the land.

  • A person who is associated wth that person, at a elevant time or

  • A person who is party to, or concerned in an arrangement.

An arrangement is covered by or , 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.

The definition of chargeable person is at .