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12(1)  Profits or losses arising out of land in the case of a concern to which this section applies are calculated as if the concern were a trade.

12(2)  Any profits arising out of the land are charged to income tax as if the concern were a trade carried on in the United Kingdom.

But this does not impose a charge to tax on a non-UK resident in the case of a concern outside the United Kingdom.

12(3)  Any losses arising out of the land are treated for the purposes of Part 4 of ITA 2007 (loss relief) as losses of a trade carried on in the United Kingdom.

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