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Private residence relief: lessons from recent case law

The lack of clarity provided by case law, coupled with a tinkering to the rules by Finance Acts, has led to an increasingly confused picture on PPR relief, writes Helen McGhee (Joseph Hage Aaronson).

The interpretation of TCGA 1992 s 222 continues to bemuse and confuse tax professionals struggling to advise our clients of a safe pathway to obtaining the relief.

The principle private residence exemption entitles individuals to relief from capital gains tax on the disposal of a property occupied as an only or main residence at some stage during ownership. Periods of both actual or deemed occupation may qualify for the relief. Lettings relief may reduce the CGT payable on the sale of a property which was at some point used as the taxpayer’s only or main residence which has also been let as residential accommodation.

Case...

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