United Kingdom · statute
Ask the law about thisMore laws of United KingdomFor machines: Markdown
In force since 2026-04-01, as the publisher states.
Copy read on 2026-11-08. The page it was read from
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.
sha256 15f162cfff8df875ac5ba2129352003bf57018515db574fedab63c200bad380a
No one has proposed a change to this act yet.
(1) In sections 164 to 167 (except in section 167(5)) references to a sale include a transfer for valuable consideration. (2) In relation to a transfer which is not a sale— “amount realised on the sale” means the value of the consideration given for the transfer, “buyer” means the person to whom the transfer is made, and “seller” means the person who makes the transfer.
Propose a changeAny question arising under section 164(3) or sections 165 to 167 (sale basis of valuation of trading stock) must be determined in the same way as an appeal.
Propose a change(1) This Chapter applies if— (a) an amount received by, or owed to, a company carrying on a trade (“the trader”) is brought into account as a receipt in calculating the profits of the trade, (b) the amount is paid or owed in a territory outside the United Kingdom, and (c) some or all of the amount is unremittable. (2) An amount received is unremittable if it cannot be transferred to the United Kingdom merely because of foreign exchange restrictions. (3) An amount owed is unremittable if it cannot be paid in the United Kingdom and— (a) it temporarily cannot be paid in the territory in which it is owed merely because of foreign exchange restrictions, or (b) it can be paid in that territory but, if it were paid there, the amount paid would not be transferable to the United Kingdom merely because of foreign exchange restrictions. (4) “Foreign exchange restrictions” are restrictions imposed by any of the following— (a) the laws of the territory where the amount is paid or owed, (b) executive action of its government, and (c) the impossibility of obtaining there currency that could be transferred to the United Kingdom. (5) Section 464(1) (matters to be brought into account in the case of loan relationships) does not prevent any amount from being brought into account in accordance with section 173 or 175.
Propose a change(1) If— (a) the trader has profits from the trade in a period of account, and (b) an unremittable amount has been brought into account as a receipt for that period, a deduction of the amount is allowed from those profits (but see subsection (5)). (2) If the trader has profits from the trade in a period of account and the total of— (a) any unremittable amounts brought into account as receipts for that period, and (b) any amount carried forward under this subsection or subsection (3) from the previous period of account, exceeds the amount of those profits, the excess may be carried forward to the next period of account. (3) If the trader does not have profits from the trade in a period of account and an unremittable amount has been brought into account as a receipt for that period, the total of— (a) any unremittable amounts brought into account as receipts for that period, and (b) any amount carried forward under this subsection or subsection (2) from the previous period of account, may be carried forward to the next period of account. (4) If an amount is carried forward under this section to a period of account in which the trader has profits from the trade, a deduction of the amount is allowed from those profits (but see subsection (5)). (5) The total amount deducted under this section from the profits from a trade in a period of account must not exceed the amount of the profits.
Propose a change(1) No deduction is allowed under section 173 in relation to an amount so far as— (a) it is used to finance expenditure or investment outside the United Kingdom, or (b) it is applied outside the United Kingdom in another way. (2) No deduction is allowed under section 173 in relation to an amount owed so far as a payment under a contract of insurance has been received in relation to it. (3) No deduction is allowed under section 173 in relation to an amount brought into account in calculating profits if relief under section 1275 (unremittable income) may be claimed in relation to that amount.
Propose a change(1) This section applies if— (a) some or all of an unremittable amount has been deducted from profits under section 173, and (b) any of the following events occurs. (2) The events are that— (a) the amount or part of it ceases to be unremittable, (b) an allowable provision for impairment loss is made in respect of the amount or part of it, (c) the amount or part of it is used to finance expenditure or investment outside the United Kingdom, (d) the amount or part of it is applied outside the United Kingdom in another way, (e) the amount or part of it is exchanged for, or discharged by, an amount that is not unremittable, and (f) if the amount is an amount owed, a payment under a contract of insurance is received in relation to the amount or part of it. (3) The amount or the part of it in question is brought into account as a receipt in calculating the profits of the trade of the period of account in which the event occurs, but only so far as— (a) it has been deducted from profits under section 173, and (b) it has not already been brought into account as a receipt in calculating the profits of the trade as a result of this section. (4) If the event is the receipt of a payment under a contract of insurance, the amount brought into account as a receipt must not exceed the amount of the payment. (5) In subsection (2)(b) “allowable provision for impairment loss” means either— (a) a debit in respect of the impairment of a financial asset (see section 476(1)) which is brought into account under Part 5 (loan relationships), or (b) a provision in respect of which a deduction is allowable under section 55 (bad debts).
Propose a change(1) In this Chapter “know-how” means any industrial information or techniques likely to assist in— (a) manufacturing or processing goods or materials, (b) working a source of mineral deposits (including searching for, discovering or testing mineral deposits or obtaining access to them), or (c) carrying out any agricultural, forestry or fishing operations. (2) For this purpose— “mineral deposits” includes any natural deposits capable of being lifted or extracted from the earth and for this purpose geothermal energy is treated as a natural deposit, and “source of mineral deposits” includes a mine, an oil well and a source of geothermal energy. (3) For the purposes of this Chapter any consideration received for giving, or wholly or partly fulfilling, an undertaking which— (a) is given in connection with a disposal of know-how, and (b) restricts, or is designed to restrict, any person's activities in any way, is treated as consideration received for the disposal of the know-how. (4) It does not matter whether or not the undertaking is legally enforceable. (5) For the purposes of this Chapter references to a sale of know-how include an exchange of know-how and any provision of this Chapter referring to a sale has effect with the necessary modifications. (6) Those modifications include, in particular, reading references to the proceeds of sale and to the price as including the consideration for the exchange.
Propose a change(1) This section applies if— (a) a company carrying on a trade receives consideration for the disposal of know-how which has been used in the trade, (b) the company continues to carry on the trade after the disposal, and (c) neither section 178 (disposal of know-how as part of disposal of all or part of a trade) nor section 179 (seller controlled by buyer etc) applies. (2) The amount or value of the consideration is treated for corporation tax purposes as a trading receipt, except so far as it is brought into account under section 462 of CAA 2001 (disposal values). (3) If the know-how is sold together with other property, the net proceeds of the sale of the know-how are treated as being so much of the net proceeds of the sale of all the property as, on a just and reasonable apportionment, is attributable to the know-how. (4) For this purpose all property sold as a result of one bargain is treated as sold together even though— (a) separate prices are, or purport to be, agreed for separate items of that property, or (b) there are, or purport to be, separate sales of separate items of that property. (5) Any question about the way in which a sum is to be apportioned under this section must be determined in accordance with section 563(2) to (6) of CAA 2001 (procedure for determining certain questions affecting two or more persons) if it materially affects two or more taxpayers. (6) For this purpose a question materially affects two or more taxpayers if, at the time when the question falls to be determined, it appears that the determination is material to the liability to tax (for whatever period) of two or more persons.
Propose a change(1) This section applies if — (a) a person carrying on a trade receives consideration for the disposal of know-how which has been used in the trade, and (b) the know-how is disposed of as part of the disposal of all or part of the trade. (2) If the person disposing of the know-how is within the charge to corporation tax, the consideration is treated for corporation tax purposes as a capital receipt for goodwill. (3) If the person acquiring the know-how— (a) is within the charge to corporation tax, and (b) provided the consideration, the consideration is treated for corporation tax purposes as a capital payment for goodwill. (4) But the consideration is not treated for corporation tax purposes as a capital payment for goodwill if, before the acquisition, the trade was carried on wholly outside the United Kingdom. (5) If the person disposing of the know-how is within the charge to corporation tax— (a) that person, and (b) the person acquiring the know-how (whether or not within the charge to corporation tax), may jointly elect for this section not to apply (but see section 179). (6) The election must be made within two years of the disposal. (7) If— (a) an election is made under section 194 of ITTOIA 2005 (corresponding income tax provision), and (b) the person making the acquisition mentioned in that section is within the charge to corporation tax, the persons making the election under that section are treated as also making an election under this section (even though the person disposing of the know-how is not within the charge to corporation tax).
Propose a change(1) This section applies if a disposal of know-how is by way of sale and— (a) the seller is a body of persons over which the buyer has control, (b) the buyer is a body of persons over which the seller has control, or (c) both the seller and the buyer are bodies of persons and another person has control over both of them. (2) In such a case— (a) section 177 does not apply, and (b) no election may be made under section 178. (3) For the purposes of this section “body of persons” includes a firm.
Propose a change(1) This Chapter applies if— (a) a company carrying on a trade changes, from one period of account to the next, the basis on which profits of the trade are calculated for corporation tax purposes, (b) the old basis accorded with the law or practice applicable in relation to the period of account before the change, and (c) the new basis accords with the law and practice applicable in relation to the period of account after the change. (2) The practice applicable in any case means the accepted practice in cases of that description as to how profits of a trade should be calculated for corporation tax purposes. (3) A company changes the basis on which profits of a trade are calculated for corporation tax purposes if the company makes— (a) a change of accounting policy (see subsection (4)), or (b) a change in the tax adjustments applied (see subsections (5) and (6)). (4) A “change of accounting policy” includes, in particular— (a) a change from using UK generally accepted accounting practice to using generally accepted accounting practice with respect to accounts prepared in accordance with international accounting standards, and (b) a change from using generally accepted accounting practice with respect to accounts prepared in accordance with international accounting standards to using UK generally accepted accounting practice. (5) A “tax adjustment” means any adjustment required or authorised by law in calculating profits of a trade for corporation tax purposes. (6) A “change in the tax adjustments applied”— (a) does not include a change made in order to comply with amending legislation not applicable to the previous period of account, but (b) includes a change resulting from a change of view as to what is required or authorised by law or as to whether any adjustment is so required or authorised.
Propose a change(1) An amount by way of adjustment must be calculated in accordance with section 182. (2) If the amount produced by the calculation is positive— (a) the amount is brought into account as a receipt in calculating the profits of the trade, and (b) the receipt is treated as arising on the first day of the first period of account for which the new basis is adopted. (3) If the amount produced by the calculation is negative— (a) a deduction is allowed for the amount as an expense of the trade in calculating the profits of the trade, and (b) the expense is treated as arising on the first day of the first period of account for which the new basis is adopted. (4) This section is subject to— (a) section 183 (no adjustment for certain expenses previously brought into account), (b) section 184 (cases where adjustment not required until assets realised or written off), and (c) section 185 (change from realisation basis to mark to market).
Propose a changeThe amount of the adjustment is calculated as follows. Step 1 Add together any amounts representing the extent to which, comparing the two bases, profits were understated (or losses overstated) on the old basis. The amounts are— Amounts 1 | Receipts which on the new basis would have been brought into account in calculating the profits of a period of account before the change, so far as they were not so brought into account. 2 | Expenses which on the new basis fall to be brought into account in calculating the profits of a period of account after the change, so far as they were brought into account in calculating the profits of a period of account before the change. 3 | Deductions in respect of opening trading stock or opening work in progress in the first period of account on the new basis, so far as they— are not matched by credits in respect of closing trading stock or closing work in progress in the last period of account before the change, or are calculated on a different basis that if used to calculate those credits would have given a higher figure. 4 | Amounts recognised for accounting purposes in respect of depreciation in the last period of account before the change, so far as they were not the subject of an adjustment for corporation tax purposes, where such an adjustment would be required on the new basis. Step 2 Then deduct any amounts representing the extent to which, comparing the two bases, profits were overstated (or losses understated) on the old basis. The amounts are— Amounts 1 | Receipts which were brought into account in a period of account before the change, so far as they would not have been so brought into account if the profits had been calculated on the new basis. 2 | Expenses which were not brought into account in calculating the profits of a period of account before the change, so far as they— would have been brought into account for a period of account before the change if the profits had been calculated on the new basis, and would have been brought into account for a period of account after the change if the profits had continued to be calculated on the old basis. 3 | Credits in respect of closing trading stock or closing work in progress in the last period of account before the change, so far as they— are not matched by deductions in respect of opening trading stock or opening work in progress in the first period of account on the new basis, or are calculated on a different basis that if used to calculate those deductions would have given a lower figure. An amount so deducted may not be deducted again in calculating the profits of a period of account.
Propose a change(1) This section applies if, as a result of a change of basis, expenses brought into account before the change on the old basis would on the new basis be brought into account over more than one period of account after the change. (2) In such a case— (a) no adjustment is made under this Chapter, and (b) in calculating the profits of the trade no deduction is allowed for the expenses for any period of account after the change.
Propose a change(1) This section applies if there is a change of basis resulting from a tax adjustment affecting the calculation of any of the following amounts. (2) The amounts are— (a) any amount brought into account in respect of closing trading stock in the last period of account before the change of basis, (b) any amount brought into account in respect of opening trading stock in the first period of account on the new basis, and (c) any amount brought into account in respect of depreciation. (3) The receipt of the trade or (as the case may be) the expense of the trade is treated as arising only when the asset to which it relates is realised or written off.
Propose a change(1) This section applies if there is a change of basis from— (a) not recognising a profit or loss on an asset until the asset is realised, to (b) bringing assets into account in each period of account at a fair value. (2) So far as— (a) a receipt within item 1 of Step 1 in section 182 represents the fair value of an asset that is trading stock, or (b) an expense within item 2 of that step relates to such an asset, the receipt of the trade or (as the case may be) the expense of the trade is treated as not arising until the period of account in which the value of the asset is realised. (3) In the case of a receipt of the trade, this is subject to any election under section 186 (election for spreading). (4) In this section “trading stock” has the same meaning as in section 163.
Propose a change(1) If section 185 applies, the company carrying on the trade may elect for any receipt treated as arising under this Chapter to be spread over 6 periods of account. (2) The election must be made within 12 months of the end of the first accounting period to which the new basis applies. (3) If an election is made, an amount equal to one-sixth of the amount of the receipt— (a) is treated as arising, and (b) is brought into account in calculating the profits of the trade, in each of the 6 periods of account beginning with the first period to which the new basis applies. (4) But if, before the whole of the receipt has been so brought into account, the company permanently ceases to carry on the trade, the whole of the amount so far as not previously brought into account— (a) is treated as arising, and (b) is brought into account in calculating the profits of the trade, immediately before the cessation.
Propose a change(1) This section applies if— (a) an asset to which section 185 or 186 applies is transferred from one insurance company to another, (b) the transfer is made under an insurance business transfer scheme, and (c) immediately after the transfer, the transferee is UK resident or the asset is held for the purposes of a business carried on by the transferee in the United Kingdom through a permanent establishment. (2) For the purposes of section 185, the asset is not to be treated as realised by the transferor merely because of its transfer under the scheme. (3) If the transfer is of the transferor's whole business, the transferee is responsible under section 185 or 186 for bringing into account any amount required to be brought into account after the transfer.
Propose a changeThe charge to corporation tax on income applies to post-cessation receipts arising from a trade.
Propose a change(1) A post-cessation receipt is chargeable to tax under this Chapter only so far as it is not otherwise chargeable to corporation or income tax. (2) Accordingly, a post-cessation receipt arising from a trade is not chargeable to tax under this Chapter so far as it is brought into account in calculating the profits of the trade of any period. (3) A post-cessation receipt is not chargeable to tax under this Chapter if— (a) it is received by or on behalf of a non-UK resident company which is beneficially entitled to it, and (b) it represents income arising outside the United Kingdom. (4) A post-cessation receipt is not chargeable to tax under this Chapter if it arises from a trade carried on wholly outside the United Kingdom other than a company's trade of dealing in or developing UK land.
Propose a change(1) In this Part “post-cessation receipt” means a sum— (a) which is received after a person permanently ceases to carry on a trade, and (b) which arises from the carrying on of the trade before the cessation. (2) In this Chapter, except in sections 194 and 195, references to a person permanently ceasing to carry on a trade include— (a) in the case of a company, the occurrence of an event treated under section 18 of ITTOIA 2005 (companies beginning or ceasing to be within charge to income tax) as the company permanently ceasing to carry on the trade, and (b) in the case of a trade carried on by a person in partnership, the occurrence of an event treated under section 246(4) of ITTOIA 2005 (basic meaning of “post-cessation receipt”) as the person permanently ceasing to carry on the trade.
Propose a change(1) The following provisions treat certain amounts as post-cessation receipts for the purposes of this Part— section 82(6) (contributions to local enterprise organisations or urban regeneration companies), section 101(3) (distribution of assets of mutual concerns), section 108(3) (receipt of benefits by donor or connected person), section 192 (debts paid after cessation), section 193 (debts released after cessation), as qualified, where appropriate, by section 56(4) (car ... hire), section 194 (transfer of rights if transferee does not carry on trade), and section 1277 (income charged on withdrawal of relief after source ceases: unremittable income). (2) Section 95 (acquisition of trade: receipts from transferor's trade) and section 194 (transfer of rights if transferee does not carry on trade) treat certain amounts as not being post-cessation receipts for the purposes of this Part.
Propose a change(1) This section applies if, in calculating the profits of a trade for corporation or income tax purposes, a deduction is made in respect of a debt under— (a) section 55 (bad debts), or (b) section 35 of ITTOIA 2005 (bad and doubtful debts), and a person permanently ceases to carry on the trade. (2) A sum received after the cessation is treated as a post-cessation receipt so far as the deduction is made.
Propose a change(1) This section applies if— (a) in calculating the profits of a trade of any period for corporation or income tax purposes, a deduction is allowed for the expense giving rise to a debt owed by the person who carried on the trade, (b) the person has permanently ceased to carry on the trade at or after the end of that period, (c) after the cessation, all or part of the debt is released, and (d) the release is not part of a statutory insolvency arrangement. (2) The amount released is treated as a post-cessation receipt.
Propose a change(1) This section applies if— (a) a company (“the transferor”) permanently ceases to carry on a trade, (b) the transferor transfers to another person (“the transferee”) for value the right to receive sums arising from the carrying on of the trade, and (c) the transferee does not subsequently carry on the trade. (2) The transferor is treated as receiving a post-cessation receipt. (3) The amount of the receipt is— (a) the amount or value of the consideration for the transfer, if the transfer is at arm's length, or (b) the value of the rights transferred as between parties at arm's length, if the transfer is not at arm's length. (4) Any sums mentioned in subsection (1)(b) which are received after the cessation of the trade are not post-cessation receipts. (5) This section is subject to section 195 (transfer of trading stock).
Propose a change(1) When a company permanently ceases to carry on a trade, a sum realised by the transfer of trading stock is not a post-cessation receipt if a valuation of the stock is brought into account in accordance with Chapter 11 (valuation of stock). (2) In this section “trading stock” has the meaning given by section 163.
Propose a change(1) In calculating the amount on which tax is charged under this Chapter, deductions are allowed in accordance with— (a) this section, and (b) section 197, from the amount which would otherwise be chargeable to tax under this Chapter. (2) A deduction is allowed for a loss, expense or debit which, if the person carrying on the trade had not permanently ceased to do so— (a) would have been deducted in calculating the profits of the trade for corporation or income tax purposes, or (b) would have been deducted from or set off against the profits of the trade for corporation or income tax purposes, but no deduction is allowed if the loss, expense or debit arises directly or indirectly from the cessation itself. (3) No deduction for an amount is allowed under this section if the amount has been allowed under any other provision of the Tax Acts.
Propose a change(1) An amount may not be deducted more than once under section 196. (2) A deduction under that section of a loss must be made from post-cessation receipts charged for an earlier accounting period in preference to those charged for a later accounting period. (3) But this does not authorise the deduction of a loss from post-cessation receipts charged for an accounting period before the accounting period in which the loss is made.
Propose a change(1) This section applies if a post-cessation receipt is received by a company in an accounting period beginning not later than 6 years after the company permanently ceased to carry on the trade. (2) The company may elect that the tax chargeable in respect of the receipt is to be charged as if the receipt had been received on the date of the cessation (but see sections 199 and 200). (3) The election must be made before the end of the period of two years beginning immediately after the end of the accounting period in which the receipt is received.
Propose a change(1) This section applies if— (a) a company which has permanently ceased to carry on a trade makes an election under section 198 in respect of a post-cessation receipt (“the carried back receipt”), and (b) a deduction in respect of a loss has already been made under section 196 for an accounting period later than that in which the cessation occurred. (2) Nothing in section 196 (read with section 197(2)) requires or permits a deduction in respect of that loss to be allowed, as a result of the election, for the accounting period in which the cessation occurred instead of the accounting period for which the deduction has already been made. (3) But if the deduction was made for the accounting period in which the carried back receipt was received, subsection (2) applies to the loss only so far as it has been deducted from post-cessation receipts other than the carried back receipt.
Propose a change(1) If a company makes an election under section 198, the additional tax is payable for the accounting period in which the receipt is received (and not for the accounting period in which the cessation occurred). (2) In subsection (1) “the additional tax” means an amount of tax equal to the difference between— (a) the amount of tax that is chargeable on the company for the accounting period in which the cessation occurred (“amount A”), and (b) the amount of tax that would have been chargeable on the company for that period if the election had not been made (“amount B”). (3) If— (a) the company has made, under section 198, one or more other elections for receipts to be treated as received in the period in which the cessation occurred, and (b) effect has been given to those elections, the effect of those elections is taken into account in determining amounts A and B.
Propose a change(1) Any receipt or other credit item, so far as it falls within— (a) Chapter 2 of this Part (receipts of trade), and (b) Chapter 3 of Part 4 so far as it relates to a UK property business, is dealt with under Chapter 3 of Part 4. (1A) Subsection (1) does not apply in the case of the long-term business of an insurance company. (2) Any receipt or other credit item, so far as it falls within— (a) this Part, and (b) Chapter 4 of Part 10 (income from holding an office), is dealt with under Chapter 4 of Part 10.
Propose a change(1) Chapter 2 contains definitions relevant to the application of the Part. (2) Chapter 3 applies the charge to corporation tax on income to the profits of a UK property business or an overseas property business and contains basic rules about the calculation of the profits of such a property business. (3) Chapter 4 provides for certain amounts of a capital nature to be brought into account as receipts in calculating the profits of a property business. (4) Chapter 5 contains additional rules about the calculation of the profits of a property business. (5) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . (6) Chapters 7, 8 and 9 apply the charge to corporation tax on income to— (a) rent receivable in connection with a UK section 39(4) concern, (b) rent receivable for UK electric-line wayleaves, and (c) post-cessation receipts arising from a UK property business, and contain related rules. (7) Chapter 10 contains supplementary provisions including— (a) rules that give priority to provisions outside this Part in relation to certain matters that fall within it, and (b) rules that give priority to one Chapter of this Part in relation to certain matters that fall both within it and another Chapter of this Part. (8) This Part needs to be read with Parts 19 (general exemptions) and 20 (general calculation rules).
Propose a change(1) This Chapter explains for the purposes of this Act what is meant by— (a) a company's UK property business (see section 205), and (b) a company's overseas property business (see section 206). (2) Both those sections need to be read with— (a) section 207 (which explains what is meant by generating income from land), and (b) section 208 (which provides that certain activities do not count as activities for generating income from land). (3) In the case of a property business carried on by a company as a member of a firm, the basic rules in sections 205 and 206 are explained in section 1270(2) and (3). (4) See also section 86 of FA 2012 (which qualifies the basic rules in sections 205 and 206 for the purpose of applying the I - E rules in relation to an insurance company).
Propose a change(1) In this Act “property business” means a UK property business or an overseas property business. (2) References in this Act to a property business are to a property business so far as any profits of the business are chargeable to tax under Chapter 3 (as to which see, in particular, the rules about territorial scope in section 5). (3) Accordingly, nothing in Chapter 4 or 5 is to be read as treating an amount as a receipt of a property business if the profits concerned would not be chargeable to tax under Chapter 3.
Propose a changeA company's UK property business consists of— (a) every business which the company carries on for generating income from land in the United Kingdom, and (b) every transaction which the company enters into for that purpose otherwise than in the course of such a business.
Propose a changeA company's overseas property business consists of— (a) every business which the company carries on for generating income from land outside the United Kingdom, and (b) every transaction which the company enters into for that purpose otherwise than in the course of such a business.
Propose a change(1) In this Chapter “generating income from land” means exploiting an estate, interest or right in or over land as a source of rents or other receipts. (2) “Rents” includes payments by a tenant for work to maintain or repair leased premises which the lease does not require the tenant to carry out. (3) “Other receipts” includes— (a) payments in respect of a licence to occupy or otherwise use land, (b) payments in respect of the exercise of any other right over land, and (c) rentcharges and other annual payments reserved in respect of, or charged on or issuing out of, land. (4) For the purposes of this section a right to use a caravan or houseboat at only one location is treated as a right deriving from an estate or interest in land.
Propose a changeFor the purposes of this Chapter the following activities are not carried on for generating income from land— (a) farming or market gardening in the United Kingdom (but see section 36 (UK farming or market gardening treated as trade)), (b) any other occupation of land (but see section 38 (certain commercial occupation of UK land treated as trade)), and (c) activities for the purposes of a concern to which section 39 applies (profits of mines, quarries etc).
Propose a changeThe charge to corporation tax on income applies to the profits of a property business.
Propose a change