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HMRC internal manual

Business Income Manual

Computing the amount to assess: business changes: changes in scale, nature or location of trade: relocations

A relocation is a particular change in the nature of a trade. Some businesses, especially some professions, are carried on wherever the proprietor happens to be and are not fixed to a particular locality. Examples are entertainers and professional sportspersons with a national or international reputation and practising barristers. Other businesses are ‘local’ in the sense that the business is done in a particular place (Seldon v Croom-Johnson [1932] 16TC740 at page 746).

The relocation of a local business, if substantial enough in nature, will give rise to the permanent discontinuance of one trade and the commencement of a new and different one (Fry v Burma Corporation Ltd [1930] 15TC113 at page 128).

The most relevant factor will usually be the extent to which the customer base of the trade changes.