Jurisdiction(s):
United Kingdom

Key definition

Activity definition

What does Activity mean? In radiation and environmental practice, activity has two related uses. 1) Scientific measure: the rate at which a radionuclide decays per unit time. It is defined in radiation protection legislation and standards, with the SI unit Becquerel (Bq). The Curie (Ci) may appear in legacy or supplier documentation. Activity (and activity concentration) determines whether exemption, clearance and authorisation thresholds are met, and underpins discharge limits and inventory caps across the UK and Ireland. 2) Regulated practice: a practice or operation involving radioactive material or radiation generators that may require prior regulatory authorisation. Depending on jurisdiction and risk, this may take the form...

UK Property Transactions: Distinguishing Trading from Investment, Tax Consequences, HMRC Enquiries, Mixed Motives and Tenant Transactions in Superior Interests

Published by a LexisNexis Tax expert

Practice notes

Practice Note

The tax outcome for the owner hinges on whether a property is bought, retained or sold as an investment or as part of a trading (ie dealing) venture. Land, more than many other asset classes, can be kept as an investment or treated as trading stock, and the correct classification turns on each party’s particular position—the identical deal may amount to investment for one participant and trading for someone else. This Practice Note sets out the main factors used to differentiate trading from investment Activity in relation to property. Those factors apply equally to transactions yielding gains and those producing losses. It also explains HMRC’s stance when opening enquiries into whether a property deal is trading or an investment in nature. It further addresses particular situations, such as mixed-motive transactions, taxpayers both dealing and investing, and tenants transacting in superior interests in land...

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Leigh Sayliss

Lawrence Stephens

After almost 20 years in engineering, Leigh retrained and requalified as a solicitor in 2003. He joined Lawrence Stephens in 2025. Leigh is a versatile Tax Partner and Chartered Tax Advisor with wide experience in property, corporate and employment taxes in particular. Leigh maintains a broad practice and enjoys the challenges created by the ways in which different taxes interact in real-life situations—looking for practical solutions for his clients. Leigh uses his experience as a professional engineer and his background in industry to help him bring a commercial understanding to the transactions with which he is involved. Leigh is editor of the land-related sections of “Monroe and Nock on the law of Stamp Duties”. He is chair of the CIOT Property Taxes Committee and a member of HMRC working groups in relation to Stamp Duty Land Tax and construction matters....

Web page updated on 22/05/2026

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