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] 8TC541).
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] 15TC515).
The transfer of tangible assets does not by itself amount to
succession (Watson Brothers v Lothian [1902] 4TC441, and Wilson and
Barlow v Chibbett [1929] 14TC407). Nor by itself does the passing
on of lists of trade customers (Mills from Emelie Ltd v CIR
[1919].
