“Where the activities of a taxpayer into the acquisition and sale of property are alleged to constitute the carrying on of a trade, it is necessary to determine after consideration of all the facts of the case, whether the proceeds of sales are profits of a trade, or merely accretions of capital. In the Final Report of the 1954 Royal Commission six “badges of trade” were listed as being the relevant considerations in deciding whether a transaction of purchase and sale which has given rise to a profit is, or is not to be treated as a trading transaction.”

Discuss, using the relevant case laws, the badges of trade for tax purposes.

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The criteria that distinguish trading from investment for taxation purposes They were set out by the ... View the full answer