If you are in doubt as to whether particular activities amount to or form part of trading income, you should consider alternative ways in which they may give rise to taxable income.

Profits arising from operations which cannot definitely be regarded as amounting to a trade within S989 Income Tax Act 2007 (ITA 2007) or S1119 Corporation Tax Act 2010 may nevertheless be miscellaneous income. This is confirmed by dicta in Governors of the Rotunda Hospital, Dublin v Coman [1920] 7TC517.

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