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HMRC internal manual

Company Taxation Manual

Particular bodies: unincorporated associations: transfers of trade

As an unincorporated association is not a legal entity, its trade belongs to its members (jointly).

Therefore where a trade is transferred to or from an unincorporated association, losses and capital allowances arising up to the date of the transfer can be carried forward to the new entity under CTA10/CHAPTER1/PART22 (formerly ICTA88/S343: see CTM06000 onwards) provided that the 75 per cent test of common ownership is met (i.e. 75 per cent of the members of the unincorporated association are the same as 75 per cent of the shareholders in the company).