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HMRC internal manual

Company Taxation Manual

HM Revenue & Customs
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Corporation Tax: loss-buying: SP10/91

SP10/91, a revised version of which was issued on 22 April 1996, explains the basis on which HMRC interprets ‘a major change in the nature or conduct of a trade’ (or, as appropriate, ‘business’) for various purposes, including CTA10/S673.

If a company or agent asks for clarification of SP10/91, the guidance at CTM06320 should be followed. In particular, officers should make sure they are not, in effect, being asked to advise on the structuring of a proposed transaction.

Where interpretation of the SP causes doubt or difficulty, or cannot readily be dealt with, officers may refer to CTIAA (Technical) - see ‘Technical Help’ on the left bar.