My client owns Property A which she bought 10 years ago and lived in as her main residence. Two years ago, she went travelling while letting out Property A as a holiday let. In between holiday lets, she returned to Property A for periods of time. In June 2020 (due to the pandemic) she obtained long term tenants in Property A, and moved to Property B, in which she had inherited a 50% share around 15 years ago but had never previously lived in Property B.
She has never made a main residence election on either property and has asked me to look at her CGT position with respect to both properties.
I assume that Property A will be considered my client's main residence for the majority of the period of ownership, as in the absence of a main residence election, she lived in Property A as her home and this could be easily supported by evidence. Would Property A stop being my client's main residence when she started using it as a holiday let, or could the main residence continue because she returned to the property to live in for short periods from time to time during that year, and did not have a home elsewhere?
Property A can no longer be a main residence once the long term let starts, and in any case my client was then living full time in Property B, and this could be supported by evidence in the absence of a main residence election.
Is there anything else I should be considering? Should my client now make a main residence election on Property B (with effect from June 2020) or is there no point because it is clearly her main home and this can be supported by evidence.
Thanks in advance if anyone spots anything I have missed in this scenario!