A mis-match of ownership and occupation!

Sale of property with a long completion date, meanwhile living there after exchange.

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For CGT purposes, the disposal date is the date of exchange of contracts (subject to certain exceptions).

For PRR purposes, occupation is taken as dates of occupation.

So, what about a situation where a person is selling a property and there is a gap of, say, 6 months between exchange and completion? For PRR purposes, does one take the actual dates of occupation and ownership (upto completion) for the fraction calculation, notwithstanding that the disposal date for CGT purposes was some 6 months earlier?

Thanks.

Replies (5)

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By MJShone
14th Nov 2019 16:24

Does the recent Higgins case in the Upper Tribunal help?

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Replying to MJShone:
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By richard thomas
14th Nov 2019 16:28

No, but the more recent one in the Court of Appeal may. https://www.bailii.org/ew/cases/EWCA/Civ/2019/1860.html

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Replying to richard thomas:
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By mail.taxperfect.co.uk
14th Nov 2019 16:43

Thanks, and yes that seems to answer the question. Completion date it is then...

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By MJShone
15th Nov 2019 08:25

Sorry - too much of a hurry to reply. I meant the very recent one.

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Replying to richard thomas:
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By MJShone
15th Nov 2019 08:26

Sorry - too much of a hurry to reply. I meant the very recent one.

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