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HMRC internal manual

Business Income Manual

Computing the amount to assess: business changes: succession and changes in ownership: professions and vocations

The concept of ‘succession’ applies to professions and vocations just as it does to trades. Some professions, such as that carried on by a barrister or a portrait painter cannot be the same profession if they are carried on by a different person, because they depend on the personal qualities of the individual. Other professions, such as that carried on by a general practitioner, can continue in existence despite a change in ownership (Rex v General Commissioners of Income Tax for the City of London [1942] 24TC221 at page 239).