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The word 'succession' has been carried forward from ITA 1842, enacted when business transactions were normally of a simpler character than they have since become, and the rules under ITA 1842 no doubt envisaged the transfer of the sole business of a trader to another person who had not in any way previously been involved in the ownership, and who would be expected to carry on business in much the same way as his predecessor.

Although business transactions have become very much more complicated, especially in consequence of the institution and development of limited liability companies, no definition of 'succession' has appeared on the statute book.

As a result it has been necessary for the courts to decide the matter in individual cases. Although the word 'succession' was replaced by the phrase 'change in the persons engaged in carrying on any trade, profession or vocation', the courts accepted that the phrase meant the same as 'succession' and therefore that the earlier case law continued to apply¹.