A relocation is a particular change in the nature of a trade.
Some businesses, especially professions, are carried on wherever
the proprietor happens to be and are not fixed to a particular
locality. Examples are entertainers and professional sportspersons
with a national or international reputation and practising
barristers. Other businesses are ‘local’ in the sense
that the business is done in a particular place (Seldon v
Croom-Johnson [1932] 16TC740 at page 746).
The relocation of a local business, if substantial enough in
nature, will give rise to the permanent discontinuance of one trade
and the commencement of a new and different one (Fry v Burma
Corporation Ltd [1930] 15TC113 at page 128).
The most relevant factor will usually be the extent to which
the customer base of the trade changes.
