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HMRC internal manual

Business Income Manual

HM Revenue & Customs
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Waste disposal: site preparation: entitlement of successor to deductions

S165 Income Tax (Trading and Other Income) Act 2005, S142 Corporation Tax Act 2009

Where a successor carries on the trading activities at a waste disposal site, previously carried on by the predecessor, then provided all of the relevant conditions are satisfied:

  • the successor’s trade is treated as the same trade as that carried on by the predecessor, and
  • deductions are made to the successor as if everything had been done by the successor.

The conditions are that:

  • the whole of the site in question is transferred to the successor. However, provided that the successor holds an estate or interest in the whole site, it need not be the same interest held by the predecessor;
  • the successor holds a waste disposal licence (see BIM67545) in respect of the site, at the time the successor first deposits waste material at the site.