Income Tax (Trading and Other Income) Act 2005 section 264

UK property business

Section 264 defines what constitutes a person's "UK property business" by treating all their UK land income activities as a single business for tax purposes.

• A UK property business encompasses every business a person carries on to generate income from land in the United Kingdom, plus any one-off or casual transactions entered into for the same purpose
• All of a person's UK property income activities — whether professionally organised lettings, informal lettings, or isolated transactions — are treated as forming one single business
• The concept of a "property business" is broader than a trade: it includes activities that the person might not ordinarily regard as a business, such as a single letting of a spare property
• Where a business is carried on, or a transaction is entered into, in partnership, separate rules under section 859 determine how the "one business per person" principle applies