BIM80650 - Computing the amount to assess: business changes: succession and changes in ownership - factors affecting succession
A transfer for value of the goodwill of a trade is strong evidence that the purchaser has succeeded to the trade (Thomson and Balfour v Le Page (1923) 8 TC 541).
But it is not conclusive since goodwill, along with other assets of a business, may have value even if the business has lost the identity necessary for succession (Reynolds, Sons & Co Ltd v Ogston (1930) 15 TC 515).
The transfer of tangible assets does not by itself amount to succession (Watson Brothers v Lothian (1902) 4 TC 441, and Wilson and Barlow v Chibbett (1929) 14 TC 407). Nor by itself does the passing on of lists of trade customers (Mills from Emelie Ltd v IRC (1919) 12 TC 73).