Income Tax Act 2007 section 517F

Profits and losses

Section 517F clarifies that the rules in Part 9A dealing with profits and gains from UK land transactions apply equally to losses arising from those same transactions.

  • The provisions in sections 517B to 517E, which deal with profits and gains from UK land disposals, also apply to corresponding losses
  • Wherever the term "profit or gain" appears in Part 9A, it should be read as including a loss
  • This ensures symmetrical treatment — if a transaction would be caught by these rules when it produces a profit, it is equally caught when it produces a loss
  • Losses recognised under these provisions are treated as trading losses, mirroring the treatment of profits as trading profits under section 517E

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