Principle Private Residence Relief

PPR

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Client A received a parcel of land as a separation settlement  4 years ago. Was attempting to obtain planning permission for 4 houses including one for himself  but has now decided to sell the land. Has always lived in rental property but believes PPR should apply. Any ideas please?

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By BMJS
25th May 2016 17:54

Your client is going to be disappointed.

There would need to be a dwelling on the land, that is/was a residence of your client, for any chance of PPR.

At least the CGT will only be at 10/20%.

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By Paul D Utherone
26th May 2016 10:12

His intention at the outset was to get planning permission & develop, presumably for sale of three properties at a profit. That would suggest the potential at least for there to be a trading motive in part and income tax liability rather than CGT.

You might like to read this recent Tribunal, which admittedly went the other way but on different facts - http://www.bailii.org/uk/cases/UKFTT/TC/2016/TC05104.html

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Replying to Paul D Utherone:
By Paul D Utherone
26th May 2016 12:18

I should add that the case was re penalties, but includes discussion re trading or CGT re property and intention that might be relevant.

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