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HMRC internal manual

Business Income Manual

Computing the amount to assess: business changes: one trade or more than one trade: same trade by different entities

None of these rules apply where there is a difference of identity between the persons and body of persons carrying on the two activities. In particular, where similar activities are carried on both by a partnership and a partner on his or her own account each will carry on a separate trade.

Equally, where two companies within the same group carry on similar activities each will carry on a separate trade. Nor can a company’s trade be part of a ‘group trade’ carried on by a group of companies as a whole.