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Commentary

B2.607 Investments held as stock

Business tax

The question whether stocks and shares, interests in land and other assets are to be regarded as trading stock or capital assets depends on the nature of the business. In the case of companies whose activities are restricted to the holding of investments and the receiving of interest therefrom, the assets constituting the investments are treated as fixed assets. However, in the case of companies which carry on the business of buying and selling stocks and shares or other assets, with a view to making a profit, such assets are treated as stock. Thus in Scottish Investment Trust Co Ltd1 an assessment was made upon the company to include profits on investments as a trading item. The General Commissioners found that these profits were correctly assessed, holding that the variation of investments was an integral feature of the business. Where, however, the main business of the company was insurance,

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