Introduction Overview Overview Section 951: Part of trade treated as separate trade
2828.This section deals with transfers of parts of trade. It is based on section 343(1) and (8) of ICTA.
2829.This section refers to “activities” of a trade and “part” of a trade, as these expressions have been the subject of judicial comment: see Falmer Jeans Ltd v Rodin (1990), 63 TC 55.(6)
2830.Section 344(5) and (6) of ICTA do not expressly provide that, if there has been an apportionment, only the assets and liabilities apportioned to the transferred trade are to be taken into account. Subsection (6) makes these points explicit.