Taxation logo taxation mission text

Since 1927 the leading authority on tax law, practice and administration

Cash is king

21 September 2006
Issue: 4076 / Categories: Forum & Feedback

I have a client who, in the 2005-06 tax year, put £200,000 into foreign currency accounts and has converted money into foreign currencies, or from one currency to another, two or three times per month over the course of the year, with a result that he has increased his investment by between £20,000 and £25,000.

I have a client who in the 2005-06 tax year put £200 000 into foreign currency accounts and has converted money into foreign currencies or from one currency to another two or three times per month over the course of the year with a result that he has increased his investment by between £20 000 and £25 000.
I do not think that the 'gains' can be treated as capital gains but I am concerned as to whether they would amount to the 'carrying on of a trade'. I would be very pleased to receive Taxation readers' views as to whether this 'profit' is taxable and if not now whether if things continue they might be in the future.
Query T16 881                                                — Midas.


Reply by S.W.I.:

Whether the transactions amount to trading is a question of fact. Midas needs...

If you or your firm subscribes to Taxation.co.uk, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.

back to top icon