A question on PPR - is it possible to have NO ppr at all , ie be stateless from PPR point of view
Example, you live in rented house A and the tenancy ends. You then move into an owned property X for a short time, and then move into another rented house B in a different area. Is your owned property your PPR for that short period between the tenancies on house A and house B. Assume you own no other property, other than X, and the tenancies do not overlap.
On the face of it, you live in property X, there is no other house that could be a PPR so yes. On the other hand, could HMRC say that as the period of occupation is short, you have no PPR for the time you are in the owned property? But does No PPR exist as a concept?
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Provided the re-locations were genuine (i.e. not contrived to create a PPR property) I believe that on the facts you state property X would be the PPR from the date you move in until you sell it or opt for another property to be your PPR.
What was happening with
the owned property you are looking to back into PPR for the other periods?
Why was the owned property not being lived in?
Was it a BtL that was fotuitously free when the client was between rented properties, or something else?
How long was the owned property actually lived in?
I don't see why not
If a builder bought a house to do up, lives there for say 3-6 months while doing it up (on the vague hope that this might make it tax free) and then sells it and moves on to the next one, this would not qualify for PPR exemption (and I understand would be liable to income tax in any case). If he had no other place to call home, then I guess he would have no official PPR.
One of my clients keeps asking me if he can do this (and assures me all of his friends are doing it of course). I have told him several times it would not qualify as his PPR for cgt purposes, although it may be the only place he can call home.
You might find your answer here...
https://www.accountingweb.co.uk/article/principal-private-residence-relief-tips-and-advice/539825
A couple of weeks ago I wrote an article on PPR. The text said that....
We are so used to saying that the sale of a main residence is CGT-free that we are in danger of forgetting that there are two conditions for a claim to succeed:-
The property must not have been purchased for the sole reason of making a profit (s 224(3)) TCGA 1992The property must be an individual's only or main residence throughout the period of ownership (s 222(1))
and...
HMRC are supposed to not look at length of ownership instead valuing quality even stating in the HMRC’s Capital Gains Tax Manual at CG64441 that ‘occasional and short residence can make a residence; but the question is one of fact and degree’.
However, in practice, the longer the better does seem to be the rule. If you look at recent cases brought before tribunals you will find that HMRC do not appear to like situations where a property is being renovated before sale and as such can only be lived in for a short period. They particularly do not like it if two properties are owned at the same time before one is sold.
In the Any Answers questions we are not looking at two owned properties and on the face of it we are not looking at a building and selling situation. ACDWeb is right tho... more needs to be asked for a full answer.... its intention that is important.