According to the Royal Commission on the Taxation of Profits and Income (see ¶200-600):
‘If the property is worked up in any way during the ownership so as to bring it into a more marketable condition, or if any special exertions are made to find or attract purchasers, such as the opening of an office or large-scale advertising, there is some evidence of dealing. For when there is an organised effort to obtain profits there is a source of taxable income. But if nothing at all is done, the suggestion tends the other way.’
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