The latest private client developments that matter, by experts at Mishcon de Reya.
Higgins: period of ownership for PPR purposes
The facts in D Higgins v HMRC [2019] EWCA (Civ) 1860 are as follows. In 2006 the appellant entered into a contract for the purchase of an off-plan apartment or ‘a space in a tower’ as described by the First-tier Tribunal (the FTT). The property purchase did not complete until 5 January 2010 having been delayed by the 2008 credit crunch. Between July 2007 and January 2010 the appellant had no main residence and upon completion of the new purchase in January 2010 and for the subsequent two years he occupied the property as his main residence. The appellant exchanged contracts for the sale of the property on 15 December 2011 and the sale was completed on 5 January 2012. HMRC levied a capital gains...
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The latest private client developments that matter, by experts at Mishcon de Reya.
Higgins: period of ownership for PPR purposes
The facts in D Higgins v HMRC [2019] EWCA (Civ) 1860 are as follows. In 2006 the appellant entered into a contract for the purchase of an off-plan apartment or ‘a space in a tower’ as described by the First-tier Tribunal (the FTT). The property purchase did not complete until 5 January 2010 having been delayed by the 2008 credit crunch. Between July 2007 and January 2010 the appellant had no main residence and upon completion of the new purchase in January 2010 and for the subsequent two years he occupied the property as his main residence. The appellant exchanged contracts for the sale of the property on 15 December 2011 and the sale was completed on 5 January 2012. HMRC levied a capital gains...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
