CTM04730 | Corporation Tax: trading losses - relief against total profits: restrictions for farming companies - commencement and cessation
From HM Revenue & Customs · Company Taxation Manual
() does not deny relief under where a company's trade of farming or market gardening was set up and commenced within the period of five years before the beginning of the accounting period for which relief is claimed.
However where:
the company has succeeded to the trade, and
the predecessor's trade has not been treated as discontinued for the purposes of capital allowances and charges because of ,
the trade is treated as a continuous trade for S48 purposes.
There is guidance on at onwards which deals with company reconstructions without change of ownership. See for companies controlled by a spouse where a trade transferred between the parties is a continuous trade.