In addition to the Let Property Campaign we covered last month, HMRC have been pursuing a number of cases through the courts in connection with claims to “Principal Private Residence Relief” (PPR).
HMRC have had a lot of success in denying relief particularly where the taxpayer has been unable to prove that a period of occupation amounted to “some degree of permanence” , “some degree of continuity or some expectation of continuity”.
Having said this we would stress that the mere fact that a residence is only occupied for a short period is not necessarily an indicator that PPR relief would not be allowed.
If you own more than one residence and anticipate selling one in the near future and would like advice on the possibility of obtaining PPR relief then please do contact us and we will be able to advise on the requirements to be satisfied to secure PPR relief.
Finally, don’t forget that if you do own and occupy more than one residence simultaneously (e.g. a holiday home) you would have an opportunity to elect which property should be regarded as your PPR for CGT purposes.
This requires an election to be made within two years of the acquisition of the second residence and you should contact us a soon as you acquire a second residence so that we can advise you and make any necessary election on your behalf.