BIM80665 | Computing the amount to assess: business changes: succession and changes in ownership - apportionment of profits

Accounts may not be made up to and from the date of succession. Where accounts cannot be made up with reasonable accuracy, the account for the period which includes the date of change should, where the cessation and commencement provisions operate, normally be apportioned on a time basis on the lines laid down in S203 Income Tax (Trading and Other Income) Act 2005 (BIM81065). But special factors (for example, seasonal fluctuations in the net profits or expenses which are appropriate to one part only of the whole period covered) may mean that the result obtained is inequitable. In such cases an apportionment on other lines may be agreed, if those lines are fair and reasonable and give results acceptable to both the proprietors concerned.