Case Law

In Gordon & Blair Ltd v IRC 1962 40 TC 358 the company ceased its brewing operations and began to sell beer supplied to its own specifications by another brewery. It was held that this represented a discontuinance of the old trade and the commencement of a new trade.

In Rolls Royce Motors Ltd v Bamford 1976 STC 162 approximately 20 percent of the activities transferred to a new company. It was held that the transferred activities carried on by the new company represented a new trade.