Commentary on Sections Part 2: Charge to corporation tax: basic provisions Chapter 5: Supplementary Section 33: Trade includes office
143.This section provides that trade includes an office in Part 2 of this Act, subject to context. It is based on section 6(4) of ICTA which applies the definition of “trade” in paragraph (b) of that subsection to various provisions of ICTA, except in so far as the context otherwise requires.
144.The reference to “carrying on a trade” in paragraph (b) is new. It reflects one of the usages of “trade” in Part 2.
145.The interpretation does not refer to employment or vocation. The treatment of vocations is discussed in Change 2 in Annex 1. A company does not hold an employment but it is not uncommon for a company to hold an office such as that of company secretary and the charge to corporation tax on income from an office is set out in section 969.
146.Section 969 applies the charge to corporation tax on income under section 2 to income from the holding of an office.