Section 517E — Income Tax Act 2007: Disposals within section 517D: profits treated as trading profits

Disposals within section 517D: profits treated as trading profits 517E 1 The relevant amount is to be treated for income tax purposes as profits of a trade carried on by the chargeable person.

2 If the chargeable person is non-UK resident, that trade is the chargeable person's trade of dealing in or developing UK land.

3 But subsection (1) does not apply to an amount so far as it would (apart from this section) be brought into account as income in calculating profits (of any person)—

a for income tax purposes, or b for corporation tax purposes.

4 The profits are treated as arising in the tax year in which the profit or gain is realised.

5 In this section the “ relevant amount ” means so much (if any) of the profit or gain mentioned in section 517D(1) as is attributable, on a just and reasonable apportionment, to the relevant UK assets.

6 In this section “ the relevant UK assets ” means any land in the United Kingdom from which the property mentioned in section 517D(1) derives any of its value (at the time of the disposal mentioned in that subsection).

7 This section applies in relation to gains which are capital in nature as it applies in relation to other gains.