The ‘transaction in land’ provisions introduced in FA 2016 (into ITA 2007 Pt 9A) are said to be rather wide and have the effect under two of the four ‘either or’ conditions A to D to charge a profit realised on the disposal by an individual of UK land ‘acquired with the sole or main aim of realising a gain from disposing…’ to income tax rather than capital gains tax.
While there are property investors who solely seek rent returns and others who solely seek betterment of the value of the properties leading to a sale at the peak – it is my understanding that most are in it for both – that is looking for an acceptable return of rent to generate ongoing income but also for a long-term increase of the property value which they may sell ‘one day’.
With many property...
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