Rent receivable in respect of a UK electric-line wayleave is subject to income or corporation tax as property income and for income tax purposes the tax is charged on the full amount of the profits arising1. This applies unless the receipts are also taxable as trading income under ITTOIA 2005, ss 3–259, Pt 2 or CTA 2009, ss 34–201, Pt 3 which takes priority2.For income tax purposes the person liable
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