Where interest or a dividend satisfies at least one of the three tests set out in BIM40805 and so has the character of a trade receipt it is then necessary to consider further whether it:

may actually be taxed as a trade receipt for all purposes, or

should be taxed under another head of charge, for example as property income, but may be regarded as a profit of the trade solely for the purpose of giving relief for trading losses.

Trade profit solely for loss relief purposes

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