B1.425 Whether the realisation of assets is a trade
The realisation of assets can take place in many scenarios which could include trading in those assets but could also be situations where the assets are being realised on the cessation of a trade (see below), by personal representatives of a deceased person (see B1.426) or by a company set up for the purpose of realising the assets.
Profits from winding up or realisation of assets
Trading transactions may take place in the course of winding up a trade and the profit from any such transaction is assessable to tax. The mere realisation of assets does not constitute trading; it depends entirely on the operations involved in the realisation whether trading has been carried on.
Important points for consideration generally are:
- Ìý
•ÌýÌýÌýÌý whether purchases were made in connection with or with a view to the more advantageous disposal of the assets1
- Ìý
•ÌýÌýÌýÌý whether any actions were performed or contracts entered into which complicated the matter of realisation2, or
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