The charge to income tax under the old Sch. A was on ‘annual profits’ (‘annual profits and gains’, for income tax purposes, prior to 1998–99 and for corporation tax, prior to 1 April 1998), an expression which does not extend to chargeable gains (ICTA 1988, s. 833(1)). A similar distinction seems to be retained within the context of a ‘property business’ under ITTOIA 2005, Pt. 3. Thus, the principle that a ‘once and for all realisation of the capital value’ of land is outside the charge to income tax still holds good (see McClure (HMIT) v Petre [1988] BTC 377, .10 below and Lowe v JW Ashmore Ltd [1971] Ch 545, .20 below).

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