BIM75715 - Trading losses: restriction of relief: change in conduct of trade

ICTA88/S384 (3) provides that where there is a change in the manner in which a trade, profession or vocation is being carried on during a year of assessment it is to be treated as being carried on throughout that year in the same way as it is being carried on at the end of the year.

Thus:

• where a trade, in previous years, was not carried on on a commercial basis with a view to the realisation of profits; and
• there was a change during the year of assessment in the way in which the trade is being conducted, so that by the end of the year of assessment, or at the date of cessation if earlier, steps have been taken to carry on the activity on a commercial basis.

ICTA88/S384 does not operate to deny relief for that year.