Beta This part of GOV.UK is being rebuilt – find out what this means

HMRC internal manual

Business Income Manual

From
HM Revenue & Customs
Updated
, see all updates

Computing the amount to assess: business changes: succession and changes in ownership: succession and part-trades

Succession arises only where there is a change in the persons engaged in carrying on ‘a trade’, that is, the whole of a trade. It is not possible to succeed to part of a trade (Stockham v Wallasey UDC 95LT834). So in considering whether there has been a deemed cessation and a deemed commencement, the first step must be to establish that the transferred activities represented the whole of a trade which was being carried on by the predecessor (either the predecessor’s sole trade or a separate trade from any other being carried on by the predecessor (BIM80530)).