CTM06750 | Corporation Tax: loss buying: major change in the business of a transferred company: major change

CTA10/S676AC

For the purposes of CTA10/PART14/CHAPTER2A, a major change in the business of a company includes any of the following (CTA10/S676AC (1) and S676AC (2)):

• A major change in the type of property dealt in, or services or facilities provided in the trade or business concerned;

• A major change in customers, outlets or markets of the trade or business concerned;

• A major change in the nature of the investments held by the company for the purposes of an investment business;

• Any other major change in the nature or conduct of any trade or business carried on by the company;

• A major change in the scale of any trade or business carried on by the company;

• Beginning or ceasing to carry on a particular trade or business.

A major change in the business includes a change that was the result of a gradual process which began before the required period (CTA10/S676AC (3)).

Where two companies were related immediately before the change in ownership, any transfers of a trade, business, or any property between the two companies, at a time when they are still related, will be disregarded for the purposes of determining whether there has been a major change in the business of either (CTA10/S676AC (4)).

A trade includes an office for the purposes of this test (CTA10/S676AA (5)).

Further guidance on major changes in the nature or conduct of a trade, specifically, is provided at CTM06370.