289-960 Changes in partnership: income tax treatment
The partnership’s trade (as opposed to the notional trade carried on by the partner; see ¶289-795) is not treated as ceasing unless there is a complete change in the persons carrying it on.
Where there is a complete change in the composition of the partnership, taxable profits are calculated as if the trade had been permanently discontinued, even where the trade continues under new ownership. Where this is the case, the partnership is treated as if the trade had been permanently discontinued and a new one set up and commenced at the date of the change. The normal rules relating to commencements and cessations of trade apply.