BIM20290 - Trade: badges of trade: company formed for the purpose of the transaction
The existence of a registered syndicate, or a company formed solely or mainly for the purpose of the particular transaction, is evidence in favour of trading.
For example, in Californian Copper Syndicate (Limited and Reduced) v Harris  5TC159 a company was formed, inter alia, to acquire and resell mining property and did in fact buy, develop and sell such property at a profit. The purpose for which it was formed, in conjunction with its actions, was among the factors which led the court to find that the company had traded.
By way of contrast, in Tebrau (Johore) Rubber Syndicate Ltd v Farmer  5TC658 an opposite conclusion was reached. The court held that although a profit on disposal had been realised there was no evidence that the company had intended make profits from buying and selling, as distinct from developing and working, the plantations.
See also CIR v Toll Property Co Ltd (in liquidation)  34TC13.