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