Spring Budget 2024 – Non-dom no more

Given that the Chancellor has previously defended the rules around non-UK domiciled individuals (or ‘non-doms’) by raising concern over the mobility of such individuals and claiming that he “would rather wealthy foreigners spent their money in Britain”, the announcement today was somewhat out of character… although some may claim it as a pre-Election gimmick, preventing […]

It’s the quality not the quantity!

A change in personal circumstances can have tax implications, such as affecting the availability of capital gains tax principal private residence (PPR) relief. For example, a house might be occupied for only a short time before sale, due to a change of plans following a relationship breakdown. ‘Safe’ occupation? A common question asked by house […]

Claiming private residence relief: A sting in the tail?

The concept of capital gains tax (CGT) relief on the disposal of an individual’s home is straightforward enough. However, in practice errors by taxpayers (and agents) in private residence relief claims are seemingly common. In its ‘Capital Gains Tax for Land and Buildings Toolkit’ (tinyurl.com/HMRC-L-B-Toolkit), HM Revenue and Customs (HMRC) describes the omission of chargeable […]

PPR and lettings relief: The clock is ticking…

Apparently, the ‘Doomsday Clock’, which measures the likelihood of a man-made global catastrophe, currently stands at two minutes to midnight. Fortunately, there’s a little more time to plan for a forthcoming restriction to an important tax relief. ‘Doomed’ relief? Most homeowners will avail themselves of main residence relief (commonly known as ‘principal private residence relief’ […]

Private Residence Relief: HMRC’s ‘Off-Plan’ Arguments Off Target!

A private residence relief case involving an individual’s delay moving into a dwelling whilst it was being built. The extent to which capital gains tax (CGT) principal private residence (PPR) relief is available on the disposal of an individual’s only or main residence is straightforward to establish in most cases. However, differences in interpreting the […]

Private Residence Relief: When ‘Quality Trumped Quantity’!

Most individuals who dispose of their dwelling-house expect that any capital gain will be subject to private residence relief. Many of them are correct, but unfortunately some are left disappointed. Private residence relief broadly applies to gains accruing to individuals on the disposal of (or of an interest in) all or part of a dwelling […]

Private Residence Relief: Tables Turned On HMRC!

Individuals who dispose of a dwelling house sometimes find themselves in disputes with HM Revenue and Customs (HMRC) over whether private residence relief (PRR) is due on the disposal of the property for capital gains tax (CGT) purposes (under TCGA 1992, s 222). Numerous cases have reached the courts and tribunal over the years. Burden […]

Private Residence Relief: Another Disappointed Taxpayer

Private residence relief (PRR) for capital gains tax (CGT) purposes is potentially very generous. For example, a UK resident individual who is a higher rate taxpayer is liable to CGT on a residential property gain at 28% (for 2017/18). However, if PPR is available in full, the individual’s gain on disposal is not a chargeable […]

Private Residence Relief: Another Disappointed Taxpayer

Private residence relief (PRR) for capital gains tax (CGT) purposes is potentially very generous. For example, a UK resident individual who is a higher rate taxpayer is liable to CGT on a residential property gain at 28% (for 2017/18). However, if PPR is available in full, the individual’s gain on disposal is not a chargeable […]