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HMRC internal manual

Capital Gains Manual

Roll-over relief: two or more trades carried on

TCGA92/S152 (8)

TCGA92/S152 (8) provides that the trade etc referred to in TCGA92/S152 (1) includes all trades etc carried on by the claimant either at the same time or successively as if they were a single trade.

Trades carried on successively SP8/81

On 18 September 1981, the Board issued SP8/81 explaining the practice to be applied where trades are carried on successively. The text of the statement is reproduced on the HMRC website

Where a trader ceases carrying on a trade and begins to carry on another trade there will often be an interval between the two events. The Statement confirms that we will regard the two trades as carried on ‘successively’ within the meaning of TCGA92/S152 (8) provided that the interval between them does not exceed three years.

If the old assets are disposed of during the interval, relief under TCGA92/S152 will be available but there may need to be a restriction under TCGA92/S152(7) (see CG60528). If the new assets are acquired during the interval relief will be available provided they are not used or leased for any purpose before the new trade commences and they are taken into use for the purpose of the trade on its commencement.

The reinvestment time limit of TCGA92/S152(3) must still be met subject to the exercise of the Board’s discretion, see CG60620+.

TCGA92/S152 (8) & TCGA92/S158 (3)

Roll-over relief is available where the old and the new assets are used in certain specific activities which are not trades, see CG60260.