Client owned a house in France from July 2007 to when he sold it in November 2020.
He also bought a house in the UK in June 2012 which he sold in February 2021.
So he had 2 houses from June 2012 but no elections were made as to which house was his PPR.
He lived in France full time from 2007 to June 2012 and was a french tax resident. So France was his PPR from July 2007 to June 2012.
He moved back to the UK to live in 2012 and became UK tax resident at that point and started doing UK tax returns. Although no election was made as to which was his PPR all the facts indicate his UK home was his PPR from June 2012 onwards using the criteria listed HMRC's CG64545 plus other facts.
He lived in the UK house full time for 2 years from June 2012 to June 2014 and after that spent approximately 4 months a year in France at his French House and 8 months a year at his UK house. The french house was not rented out. The UK house was rented out for around 90 days a year but was available to rent for 4 months a year.
I am trying to work out how much PPR relief he will get on the 2 houses.
I believe that with the french house he will get PPR relief for the 5 years he lived there full time (July 2007 to June 2012) plus last 9 months. So period of ownership 161 months PPR relief for 69 months so 42.8%. I don't think the new rules from April 2015 will change this and anyway he spent more than 90 days in France in 2021 tax year
On the UK I estimate PPR relief for 2 tax years years (2012 to 2014) plus 8 months a year for 6 tax years years (2014 to 2020) plus last 9 months of ownership. So period of ownership 104 months PPR relief for 81 months so 77.8%