Northern Ireland Court of Appeal.

Judgment delivered 23 September 1982.

Corporation tax – Relief for trading losses – Change in ownership of company – Whether set-off of losses precluded by major change in nature of conduct of trade – Changes in method of disposal of products – What constitutes a ‘major change’ – Income and Corporation Taxes Act 1970, sec. 177(1); 247(1); 483.

  This was an appeal by the Crown from a decision of the Special Commissioners that a company retained its entitlement to set off its trading losses because there had been no ‘major change’ in its customers, outlets or markets.

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