Where the exploitation of films and sound recordings does not amount to a trade, the profits from that exploitation (the ‘non-trade business’) are nevertheless chargeable to income tax under ITTOIA 2005, s. 609 on the person receiving or entitled to the income (ITTOIA 2005, s. 611) on the full amount of income arising therefrom (ITTOIA 2005, s. 610). ‘Exploitation’ means the deriving of an income from the rights relating to the films or recordings, rather than their sale.

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