Principal private residence relief available: R Eyre and another v HMRC[2025] UKFTT 461 (TC) (23 April) is not the first case on CGT private residence relief where HMRC have challenged availability of the relief on the basis that there has been a venture in the nature of a trade and it is unlikely to be the last.
Mr and Mrs Eyre purchased a house in Chelsea for a little under £10m. They demolished the property building a new house on the same site which they sold for just over £27m. As the couple owned another property in Holland Park they elected to treat the Chelsea house as their main private residence for CGT from the date they moved in following its redevelopment. Their tax returns were submitted on the basis that the property was their principal private residence and the gain was apportioned on a...
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Principal private residence relief available: R Eyre and another v HMRC[2025] UKFTT 461 (TC) (23 April) is not the first case on CGT private residence relief where HMRC have challenged availability of the relief on the basis that there has been a venture in the nature of a trade and it is unlikely to be the last.
Mr and Mrs Eyre purchased a house in Chelsea for a little under £10m. They demolished the property building a new house on the same site which they sold for just over £27m. As the couple owned another property in Holland Park they elected to treat the Chelsea house as their main private residence for CGT from the date they moved in following its redevelopment. Their tax returns were submitted on the basis that the property was their principal private residence and the gain was apportioned on a...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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