As noted, from 2005–06 onwards, income tax is charged on the full amount of the profits arising in a tax year of a ‘property business’ (s. 268 and 270). If a taxpayer does not draw up their property business accounts to 5 April, apportionment of two years’ accounts will be required to determine the profit or loss for the tax year. HMRC’s view is that apportionment must be made on a daily basis (PIM 1010). However, see ¶289-000 for property income belonging to a partnership carrying on a trade or profession.

A ‘property business’ means a ‘UK property business’ or an ‘overseas property business’ (s. 263).

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