Member Since: 1st Oct 2009
Mark Ward qualified with a large firm in 1989, having previously worked in the tax departments of a small and a medium size firm. He has been lecturing on a wide variety of tax matters for 30 years to qualified practitioners and industry specialists in the UK and overseas.
23rd Oct 2023
With respect, that last point is exactly the inference from UT's decision - it matters not that the Lees may have, or may not have had an existing PR when they bought the 'plot' since they could sell their existing residence within 9 months of moving into the developed property and still claim PRR on the entire gains for both the former and latter. UT's decision simply ignores any period of ownership of the plot prior to the completion of and moving into the new home.
I absolutely agree with all comments referencing trading and intention at purchase, and would have expected a greater emphasis on both from HMRC, given the 14 month period of occupation. I can only surmise they thought their basic argument was more than sufficient to deny PRR on the whole gain.
19th Sep 2023
Schoolboy error on my part! Galaxian is quite right. Many thanks for spotting this. Mark