torblednam
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From https://www.charteredaccountants.ie/taxsource/1997/en/act/pub/0039/tb/sec0021-1-tb.html
Guidance as to what constitutes “trading” is available from case law and from a set of rules known as the Badges of Trade
From https://www.accaglobal.com/my/en/te...dges-of-trade.html#THE-NUMBER-OF-TRANSACTIONS
THE NUMBER OF TRANSACTIONS
A single transaction can amount to a trading activity, it is more indicative if there are repeated and systematic transactions.
I cannot find an equivalent Irish source
Finally
'the Revenue Commissioners are prepared to give an opinion on the classification of income as trading in accordance with the guidelines issued in Tax Briefing Issue 48 - June 2002 on Seeking Revenue Opinions on Tax Consequences of Certain Complex or Unusual Transactions.'
Starting at the end, what's being discussed here is neither complex nor unusual; the OP would get short shrift there.
Moving on, that very ACCA source you quoted contains the following:
The way the sale was carried out
HMRC states in its guidance that it is always a pointer if a transaction follows that of a ‘undisputed trade’. The case CIR v Livingston and Others 11TC538, involved three unconnected individuals that together bought a cargo vessel. The vessel was converted into a steam-drifter and sold for a profit. The purchase was the first vessel the three individuals bought. An assessment was raised on the profit which was upheld as a trading profit. Within the decision the judge stated:
‘I think the test, which must be used to determine whether a venture such as we are now considering is, or is not, in the nature of “trade”, is whether the operations involved in it are of the same kind, and carried on in the same way, as those which are characteristic of ordinary trading in the line of business in which the venture was made.’
The source of finance
Determining the source of finance is important when deciding whether a trade is carried on. Finance taken out to purchase an asset, in the first instance may indicate that to repay the debt the asset would have to be sold.
This was demonstrated in the Wisdom v Chamberlain – CA 1968, 45 TC 92; [1969] 1 WLR 275; [1969] 1 All ER 332 mentioned above."
Revenue have looked and will look at this sort of transaction, plenty of people have tried to argue CGT treatment, particularly if they were carrying CGT losses out of the last recession. One of the key things they will be interested in is the financing.
If the OP procures finance on the basis of a stated intention to flip / sell, he absolutely will be trading. If he makes a loss (which there's a not unsubstantial chance of) you can be certain he'd be advised to return the activity as a trade and seek to set the loss against his other income...