Part 14Income tax liability: miscellaneous rules
F1Chapter A1Remittance basis
F2Business investment relief
809VECommercial trades
(1)
Section 809VD is to be read in accordance with this section.
(2)
A reference to a “trade” also includes—
(a)
anything that is treated for corporation tax purposes as if it were a trade, and
(b)
a business carried on for generating income from land (as defined in section 207 of CTA 2009).
(3)
A trade is a “commercial trade” if it is conducted on a commercial basis and with a view to the realisation of profits.
(4)
The carrying on of activities of research and development from which it is intended that a commercial trade will be derived, or will benefit, is to be treated as the carrying on of a commercial trade.
(5)
But preparing to carry on activities within subsection (4) is not to be treated as the carrying on of a commercial trade.
F3(6)
A company which is a partner in a partnership is not to be regarded as carrying on a trade carried on by the partnership.