Income Tax (Trading and Other Income) Act 2005 section 6B

Trade of dealing in or developing UK land

Section 6B defines what constitutes a non-UK resident person's trade of dealing in or developing UK land for income tax purposes, and provides broad definitions of key terms including land and disposal.

• A non-UK resident's trade of dealing in or developing UK land covers both direct dealing and development activities, as well as profits treated under separate anti-avoidance rules as arising from such a trade
• The relevant activities are dealing in UK land or developing UK land with a view to disposing of it
• Land is broadly defined to include buildings, structures, any estate, interest or right in or over land, and land under the sea or otherwise covered by water
• UK land means land situated in the United Kingdom, and the meaning of disposal follows the definition in section 517R of the Income Tax Act 2007