Annex 1: Minor Changes in the Law Change 2: Trading income: omission of references to a company carrying on a profession or a vocation: section 35 (and other sections) Corporate bodies and vocations FA 1965
Section 89(2)(j) of FA 1965 provided that “trade” includes “vocation” for the purpose of Part 4 of the Act (taxation of companies and of company distributions). (See now section 6(4)(b) of ICTA.) Notes on Clauses explain that this is because:
	an old Court decision suggests that a bookmaking business may have to be considered as a vocation rather than a trade in the strict sense.
That decision is found in Partridge v Mallandaine, 2 TC 179. That case was heard in the High Court in 1886. Today there is little doubt that a company carrying on a bookmaking business is trading.