BIM80640 - 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 (1906) UDC 95 LT 834). 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)).