THE COMMISSIONERS FOR HIS MAJESTY鈥橲 REVENUE AND CUSTOMS v (1) GERALD LEE (2) SARAH LEE [2023] UKUT 00242 (TCC)
Upper Tribunal Tax and Chancery decision of JUDGE SWAMI RAGHAVAN & JUDGE NICHOLAS ALEKSANDER on 29 September 2023
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CAPITAL GAINS TAX 鈥� Private Residence Relief 鈥� taxpayers bought land demolished existing house and build new dwelling house which they lived in as main residence then sold for gain 鈥� meaning of 鈥減eriod of ownership鈥� used in apportionment relief 鈥� held - ownership referred to that of new house as opposed to land as HMRC argued 鈥� HMRC鈥檚 appeal against FTT decision dismissed
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Published 9 October 2023