Revenue Precedent

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Revenue Precedents

Where a trade is carried on for less than 10 years and commencement of a similar trade, strictly, relief is not due as section 597(ii)(b) requires that the old trade be carried on for at least 10 years. However, section 597(ii)(a) allows relief where two trades, wholly or mainly concerned with goods or services of the same kind are carried on. This is read as applying where the trades are carried on simultaneously or successively, thus covering a cessation of one trade and the commencement of a similar trade. G10(E).