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HMRC internal manual

Business Income Manual

Computing the amount to assess: business changes: commencement: manufacturers and retailers

In The Birmingham & District Cattle by-products Co Ltd v CIR [1919] 12TC92 all of the following were found to be preparatory activities (see the stated case at page 95):

  • viewing other places of business of a similar character in other parts of the country.
  • entering into a contract for the building of a factory, and having that factory built.
  • purchasing machinery and plant for carrying on the business.
  • entering into agreements for the purchase of products to be used in the business and for the sale of finished products, and
  • engaging a foreman of works.

Having got everything ready, the trade only commenced when the company began to take in raw materials and turn out its product. This principle is applicable to manufacturing in general.

Retail shops commence trading when they first open their doors for business. This is referred to in J & R O’Kane & Co v CIR [1922] 12TC303 at pages 341-342.