Client owns a property which was until recently his and his wife’s PPR (now let) however his wife never owned it. I am proposing a transfer of equitable interest to a 99:1 basis in favour of wife who doesn’t have any income but her husband is an additional rate tax payer. If the property is sold at a gain however wife will not be able to benefit from any CGT exemption as a consequence of the house being her PPR because any gain will not be accruing in respect of a dwelling which has at some point during her period of ownership been her PPR. The same applies to residential lettings exemption. However I cannot see what is to prevent the equitable interest being transferred back to husband prior to a sale to ensure that husband the can benefit from PPR and RLE exemptions. Would anyone agree or contest that?