Income Tax (Trading and Other Income) Act 2005 section 105

Industrial development grants

Section 105 deals with the income tax treatment of industrial development grants received by a person carrying on a trade, and sets out when such grants must be brought into account as trading receipts.

  • Grants received under the Industrial Development Act 1982 or the Industrial Development (Northern Ireland) Order 1982 are generally treated as taxable trading receipts
  • Three exceptions apply: grants designated towards specified capital expenditure, grants as compensation for lost capital assets, and grants covering corporation tax liabilities
  • Where the trade is calculated on the cash basis, the capital expenditure exception does not apply, meaning the grant is taxable as a receipt
  • This section applies only to trades and does not extend to professions or vocations

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