BIM70635 - Business changes: succession and changes in ownership: partial changes in ownership

ICTA88/S113 (1) is modified in the way it applies to ‘partial’ changes in those carrying on a trade. A ‘partial’ change is one where at least one person is engaged in carrying on the trade both before and after the change. The most common examples are a change in membership of a partnership and a sole trader taking on a partner.

For years where the Current Year basis of assessment applies ICTA88/S113 (1) does not apply to partial changes in ownership, because it is disapplied by ICTA88/S113 (2). So on a partial change of ownership the cessation and commencement provisions are not applied (unless exceptionally there is at the same time an actual cessation of one trade and the commencement of a new one).

A copy of the guidance relating to pre-SA years can be obtained from CT&VAT (Technical).