PPR and ? Job Related Accommodation

PPR and ? Job Related Accommodation

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My Client owned his only residence until 1980 when he was required to move to Northern Ireland to take up a role with a University there. In 1984, that role ended and the Inspectorate of Schools sent him to Devon where he resided in a rental property. He ultimately purchased the rental property in 1987.

He is now selling his original home, having never re-occupied it.

Until some point between 1984 and 1987, he had intended to return to his original residence which he had lived in until 1980.

If the client is able to confirm that in the case of both appointments the properties he lived in at the time would have qualified as job related accommodation, given his intention to re-occupy his original main residence, presumable the period until his intention changed would qualify for relief.

This seems to be the case per TCGA 1992 S222(8) and also the Revenue CGT manual at CG64558.

If on the other hand, we cannot conclude that the accommodation in respect of each posting was job related, then presumably no relief (apart from the final 3 years) will be forthcoming. This would seem to follow S223(3)(c). Even though up to four years could be exempted, the fact that he never re-occupied it would preclude any relief?

Any comments gratefully received.

SP

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