Commentary

B1.447 Dealings in futures, options and swap contracts

Business tax
Business tax | Commentary

B1.447 Dealings in futures, options and swap contracts

Business tax | Commentary

B1.447 Dealings in futures, options and swap contracts

Clearly the usual tests apply in determining whether dealings in futures amount to trading. In practice, HMRC appears to have adopted a strict approach to the question of what constitutes a trading transaction in this context. In particular, it has been officially emphasised that 'relatively infrequent' transactions, transactions undertaken to hedge specific investments and purely speculative transactions would not normally be regarded as trading transactions1. This is reinforced by the guidance in the Business Income Manual2 which states that normally transactions by individuals and companies in financial assets, such as shares, options

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