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HMRC internal manual

Business Income Manual

Computing the amount to assess: business changes: one trade or more than one trade: decided cases

There are a small number of cases where a trader has been accepted as carrying on more than one trade. The following show how different the activities must be:

CIR v William Ransom & Son Ltd [1918] 12TC21 herb growing, manufacturing chemists
Scales v George Thompson & Co Ltd [1927] 13TC83 Lloyd’s underwriter (through an agent), running a fleet of ships
Lewis Emanuel & Son Ltd v White [1965] 42TC369 fruit and vegetable importers, securities dealers
Scorer v Olin Energy Systems Ltd [1985] 58TC592 ship chartering, engineering

By contrast, in the following cases the taxpayer was found to be carrying on a single trade. They underline the difficulty of arguing for more than one trade:

The Howden Boiler and Armaments Company Limited v Stewart [1924] 9TC205 boiler making, shell manufacturing
CIR v Turnbull Scott & Co [1924] 12TC749 managing ships on commission, managing neutral ships for the Government at a fixed fee
Cannon Industries Ltd v Edwards [1965] 42TC625 manufacturing gas appliances, assembling electric food mixers
North Central Wagon and Finance Co Ltd v Fifield [1953] 34TC59 selling railway wagons, letting railway wagons
C Connelly & Co v Wilbey [1992] 65TC208 running an accountancy firm in offices in two different towns