BIM80540 | Computing the amount to assess: business changes: one trade or more than one trade: decided cases
From HM Revenue & Customs · Business Income Manual
There are a small number of cases where a trader has been accepted as carrying on more than one trade. The following show how different the activities must be:
| Case | - |
|---|---|
| CIR v William Ransom & Son Ltd [1918] 12TC21 | herb growing, manufacturing chemists |
| Scales v George Thompson & Co Ltd [1927] 13TC83 | Lloyd’s underwriter (through an agent), running a fleet of ships |
| Lewis Emanuel & Son Ltd v White [1965] 42TC369 | fruit and vegetable importers, securities dealers |
| Scorer v Olin Energy Systems Ltd [1985] 58TC592 | ship chartering, engineering |
By contrast, in the following cases the taxpayer was found to be carrying on a single trade. They underline the difficulty of arguing for more than one trade:
| Case | - |
|---|---|
| The Howden Boiler and Armaments Company Limited v Stewart [1924] 9TC205 | boiler making, shell manufacturing |
| CIR v Turnbull Scott & Co [1924] 12TC749 | managing ships on commission, managing neutral ships for the Government at a fixed fee |
| Cannon Industries Ltd v Edwards [1965] 42TC625 | manufacturing gas appliances, assembling electric food mixers |
| North Central Wagon and Finance Co Ltd v Fifield [1953] 34TC59 | selling railway wagons, letting railway wagons |
| C Connelly & Co v Wilbey [1992] 65TC208 | running an accountancy firm in offices in two different towns |