CGT successes, a question of values and when two become one... Edward Reed and Helin Gurel (Macfarlanes) provide this month’s private client update.
Taxpayer successes in CGT cases
Two recent taxpayer victories involving CGT provide interesting insight into the operation of reliefs on the disposal of property.
In HMRCv G Lee and another [2023] UKUT 242 (TCC) the Upper Tribunal (UT) considered principal private residence relief (PPR) (TCGA 1992 ss 222–226B).
The facts of the case were straightforward. The taxpayers bought a plot of land in October 2010 and demolished the existing house on it. They then built a new house on the land which they moved into in March 2013 before selling it in May 2014 claiming PPR on the resultant gain.
The dispute between HMRC and the taxpayers arose not over the availability but over the extent of the available relief. HMRC’s position...
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CGT successes, a question of values and when two become one... Edward Reed and Helin Gurel (Macfarlanes) provide this month’s private client update.
Taxpayer successes in CGT cases
Two recent taxpayer victories involving CGT provide interesting insight into the operation of reliefs on the disposal of property.
In HMRCv G Lee and another [2023] UKUT 242 (TCC) the Upper Tribunal (UT) considered principal private residence relief (PPR) (TCGA 1992 ss 222–226B).
The facts of the case were straightforward. The taxpayers bought a plot of land in October 2010 and demolished the existing house on it. They then built a new house on the land which they moved into in March 2013 before selling it in May 2014 claiming PPR on the resultant gain.
The dispute between HMRC and the taxpayers arose not over the availability but over the extent of the available relief. HMRC’s position...
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:
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