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Jurisdiction(s):
United Kingdom
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Key definition
Developer definition

What does Developer mean? In legal practice, a developer is the party that procures, funds and manages a property development, commissioning design and construction to deliver the completed works. A developer need not own the land or the works; it may act through a special purpose vehicle and is commonly the employer under JCT or NEC building contracts. Developers negotiate development agreements (including with public bodies), let professional appointments, and give or take collateral warranties. They usually secure planning permission and enter planning obligations (for example, section 106 agreements in England and Wales, section 75 agreements in Scotland, section 76 agreements in Northern Ireland,...

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UK corporation and income tax on property development trades: trading vs investment, profit recognition, interest restriction, ATED, and non-resident/offshore rules

Published by a LexisNexis Tax expert
Practice notes
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For anyone carrying on a trade of developing property in the UK, a primary issue is the UK tax charged on the Profits arising from that activity. This Practice Note examines what amounts to a trade and the imposition of UK corporation tax and income tax on trading profits. In this Practice Note, CGT denotes both Capital gains tax and corporation tax on chargeable Gains.

Trading vs investment

For companies within the charge to corporation tax, the corporation tax regime governing trading profits generally applies as well to the profits of a trade of property dealing and development. The specific rules for profits from trading in and developing UK land, introduced on 5 July 2016, do not apply where the relevant profit or gain is already brought into account as income for corporation tax purposes. For further details, see Practice Note: Transactions in UK land—tax rules. The corporation tax rules that apply to trading profits are distinct from those that apply to the profits of a property business, which is the business of exploiting any interest in, or right over, land as a source of rents or similar receipts...

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Charles Goddard
Charles Goddard

Charles is a solicitor at Rosetta Tax Limited, which specialises in corporate tax advice to businesses and professional services firms. He has a broad range of tax advisory expertise, having acted for a variety of UK-based and international financial institutions and listed companies. He has particular expertise in the real estate and finance sectors, with a strong focus on the taxation of insolvency and restructuring transactions.Charles was for six years until 2012 a tax partner at Berwin Leighton Paisner LLP. Prior to joining BLP, he spent eight years at Slaughter and May as a trainee and associate in their Tax group. He is recommended by both Chambers and Partners and Legal 500....

Web page updated on 22/05/2026

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Date [ date ] Parties [ name of Landlord ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Landlord) [ name of Tenant ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Tenant) [ [ name of Guarantor ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Guarantor) ] [ [ name of Mortgagee ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Mortgagee) ] Definitions Within this Deed, the terms below shall be interpreted as follows: [ Annual Rent • the annual sum reserved under the Lease; ] [ Insurance Rent • the Tenant’s share of the Landlord’s costs of insuring the Property (as set out in the Lease); ] Lease • the lease of the Property dated [ date ], entered into between (1) [ the Landlord OR [ name ...

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