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Whether there is a disposal of part of a business rather than a mere sale of an asset used in the business is a question of fact. The question will arise when only some of the assets of the business are sold. A disposal of a business asset, or assets, is not necessarily a disposal of the whole or part of a business. HMRC seeks to establish all the relevant facts, so that a complete picture of the business, including the changes which have been made to it, can be built up for the period involved. HMRC provides the example of a trader owning two shops in different towns and selling one of them. It may be possible for the trader to demonstrate that the activities at each shop form a separate, distinct and clearly identifiable part of the trade, or that entirely separate businesses are conducted from each shop¹.

The same question on whether a disposal is of the whole or part of a business arose