Special Commissioners: Dr J F A Jones CBE and Malcom J F Palmer

Decision released 13 April 2005

Terminal Loss Relief – global electronics business operating in the UK through several independently-managed divisions – whether a single trade carried on in the UK – yes, but even if wrong factory closures did not amount to the cessation of separate trades


The special commissioners dismissed an appeal by the taxpayer which sought to claim terminal loss relief under ICTA 1988, s. 393A on the basis that its independently managed divisions carried on separate trades and that factory closures within those divisions amounted to cessation of a trade.


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