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Schrödinger’s flat
KEY POINTS
- The Upper Tribunal finds no justification for only or main residence relief for a period before a flat could be occupied.
- Nothing in TCGA 1992 s 222 to s 224 could justify a narrow construction to a period of ownership.
- The contract to purchase was not conditional; it was a simple contract for sale and purchase.
- The gain was calculated by reference to the purchase and sale – the dates of acquisition and disposal for capital gains tax purposes under TCGA 1992 s 28.
- Extra Statutory Concession D49 extends the period of residence for a newly acquired dwelling but offered no relief in this case.
- Will HMRC now review previous disposals involving off-plan purchases?
Who knew that quantum physics would have a...
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