Where a taxpayer owns a property as his or her main residence but is obliged to live elsewhere in job-related accommodation, the property could be deemed not eligible for Principal Private Residence (PPR) relief. However, the relief will apply when, during the period of ownership the taxpayer:
- resides in other job-related accommodation; and
- intends to occupy the first property as his or her only or main residence at some time.
This ‘job-related’ provision is only possible if it is necessary or customary for the employee to live in accommodation provided by the employer for the better performance of their duties – it must not simply be a matter of choice.
The relief is allowed even if the first property is not occupied due to a change of circumstances, provided it has been the intention to occupy the property.
Example:
Susan occupied her main residence until 2000 when her work required her to move into qualifying job-related accommodation in Scotland.
In 2005 she was sent to work in the Devon office but occupied privately rented accommodation. She purchased that property in 2007.
In 2015 the original residence was sold, not having been re-occupied. Until 2007 she had intended to return to her main residence.
PPR relief is allowed:
1. until 2000 before the move to Scotland;
2. for the period of job-related accommodation between 2000 to 2005;
3. for 2005 to 2007 as a permitted period of absence; and
4. for the final 18 months.
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