Home Page. PFI Taxation Guidance HMRC. PFI: Scope of trade. The scope of a trade is essentially a question of fact, consideration of which is fundamental when deciding whether income is taxable as trading income or expenditure is allowable as a trading deduction (see BIM21000 onwards).
The approach adopted by the courts in deciding the scope of a trade is to establish the person's stated purpose and then consider whether or not the facts support their contention. Where the facts are at odds with the stated purpose, it may be disregarded.