If a body has customers who are not entitled to receive back
surplus amounts they have contributed to the common fund, its
transactions with them are not mutual. Tax has to be paid on them
in the usual way under Case 1 Schedule D. If the amount of trade
that is not mutual is very small it will not affect the tax
treatment of the mutual trading.
Bodies may have dealings, some of which are trading and some
not trading. Decide whether the dealings are trading transactions
before you decide whether the trade is mutual.
This distinction is covered in BIM24010.
