Income Tax Act 2007 section 307

Excluded activities: property development

Section 307 defines what counts as "property development" for the purposes of the excluded activities rules that apply to Venture Capital Trust qualifying holdings.

  • Property development means developing land where the company has or has had an interest in that land, and the main purpose is to profit from selling the developed land.
  • An "interest in land" is broadly defined to include any estate, right, or interest in or over land, including rights affecting its use or disposal, as well as conditional rights to obtain such interests.
  • Mortgage lenders and other creditors whose debts are secured against land are generally excluded from the definition of holding an "interest in land" (except for rentcharge creditors).
  • For land in Scotland, a creditor's interest in any charge or security over land is similarly excluded from the definition.

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