Income Tax Act 2007 section 517C

Disposals of land: profits treated as trading profits

Section 517C sets out how profits and gains from disposals of UK land are treated as trading profits for income tax purposes, including for non-UK residents.

• Profits or gains from UK land disposals are treated as trading profits of the chargeable person for income tax purposes
• For non-UK residents, the relevant trade is specifically their trade of dealing in or developing UK land
• The rule does not apply where the profit or gain is already being brought into account as income for income tax or corporation tax purposes
• The provision applies equally to capital gains as it does to revenue gains, and profits are recognised in the tax year in which they are realised