Income Tax Act 2007 section 517E

Disposals within section 517D: profits treated as trading profits

Section 517E sets out how profits and gains from disposals of property deriving its value from UK land are treated as trading profits for income tax purposes.

• Profits from qualifying disposals of property deriving value from UK land are treated as trading profits of the chargeable person for income tax purposes, arising in the tax year the gain is realised
• For non-UK resident persons, the deemed trade is specifically their trade of dealing in or developing UK land
• The "relevant amount" taxed is only the portion of the profit or gain that can be attributed, on a just and reasonable basis, to UK land from which the property derives its value at the time of disposal
• The provision applies equally to capital gains as it does to revenue gains, but does not apply to amounts already brought into account as income for income tax or corporation tax purposes