BIM51505 - Builders, property dealers & developers: Background
When considering whether profits derived from the acquisition and disposal of property (with or without development) are assessable as trading income, you should consider
Where there is no liability on such profits trading income, liability may in certain circumstances arise under miscellaneous income by virtue of ICTA88/S776 for Corporation Tax, ITA07/S755 for Income Tax (see BIM60300 onwards). Where appropriate in a contentious case, alternative assessments should be made under trading income and miscellaneous income by virtue of ICTA88/S776 (see BIM60385).
In cases in which the question of the valuation of land and buildings is material to the determination of trading income liability, see the guidance at BIM51560 onwards.
