Transfer of a trade

Copyright © 2026 LexisNexis
Produced by Tolley in association with Nick Wright
Corporation Tax
Guidance

Transfer of a trade

Copyright © 2026 LexisNexis
Produced by Tolley in association with Nick Wright
Corporation Tax
Guidance
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It is often necessary to transfer a trade between companies under common ownership without a change in ownership before or after a company sale or acquisition, or as part of a general group restructuring operation. See the Preparing group for sale or acquisition for a discussion as to why this may be the case.

What are the succession to trade rules?

The succession to trade rules enable trades to be transferred under common 75% ownership with the ability to carry forward tax losses into the successor company and a tax-neutral transfer for capital allowances purposes. The transfer of a trade between group members is commonly also referred to as a ‘hive down’, ‘hive up’ or ‘hive across’, depending upon the group structure in question.

Without rules to the contrary, the trade would be treated as permanently ceased in the transferor company, resulting in losses being lost and balancing adjustments in the capital allowances pools. The succession to trade rules only apply to transfers between companies and not to an individual or partnership comprised of individuals.

The

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Nick Wright
Nick Wright linkedinicon

Director, Jerroms Miller

As a member of the ICAEW and CIOT Nick specialises in technical corporate tax planning and company reorganisations advising on a variety of projects from mergers and acquisitions, management buyouts and demergers to venture capital schemes (EIS/SEIS) and employee incentives including share schemes.Nick is a regular writer for various tax journals with articles published in Taxation, Tax Adviser and ICAEW Taxline. He also contributes to Tolley's Tax Planning.Presenting regular lectures to fellow professionals through various CPD providers including MBL, CPDStore and a variety of CIOT branches.Nick is host of the Jerroms Miller Tax Hour podcast.

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  • 06 Jul 2026 13:10

Home/ Tolley Tax Guidance/ Corporation Tax / Selling or exiting the business

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