Corporation Tax Act 2009 section 37

Commercial occupation of woodlands

Section 37 provides that the commercial occupation of woodlands in the United Kingdom falls entirely outside the corporation tax system, meaning that neither profits nor losses from such activity are recognised for corporation tax purposes.

  • The commercial occupation of woodlands in the UK is not treated as a trade, or part of a trade, for any corporation tax purpose
  • Occupation of woodlands counts as "commercial" where the woodlands are managed on a commercial basis and with a view to realising profits
  • Because woodland occupation is not a trade, no trading income can be charged to tax and no trade loss relief can be claimed
  • Related provisions ensure that woodland profits and losses are also excluded from property income and from the residual income charge, placing them wholly outside the corporation tax code

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