Business Income Manual

BIM20095 - Meaning of trade: general: judicial guidance

The Tax Acts do not provide any direct statutory guidance on the meaning of 'trade' apart from the limited definition in S989 Income Tax Act 2007 (ITA 2007) and S1119 Corporation Tax Act 2010 which 바카라 사이트˜includes any venture in the nature of trade바카라 사이트™ (see BIM20060 onwards). Subject to this extra help, the word 바카라 사이트˜trade바카라 사이트™ therefore takes its ordinary meaning.

In Smith Barry v Cordy [1946] 28 TC 250 Scott LJ, who was considering what is now S989 ITA 2007, said at page 258:

바카라 사이트˜As the definition includes the very word trade without qualification, that word must be used in its ordinary dictionary sense and the other words must necessarily be intended to enlarge the statutory scope to be given to the word trade바카라 사이트™.

This is authority for the view that 'trade', for tax purposes, includes situations which fall short of being full blown, unquestionable, trades (see BIM20065).