Capital Gains Tax  

The CGT consequences of buying a 'space in a tower'

  • Explain how Principal Private Residence relief works
  • Describe what happened in the case of Mr Higgins
  • Describe how PPR flipping works

The changes which were to apply to disposals made on or after 6 April 2020 included the reduction in the final period exemption at the end of ownership from 18 months to nine months except for owners who move into a care home or who are disabled where the 36 month period of PPR exemption would have still applied, and the legislation of ESC D49

The Chartered Institute of Taxation (CIOT) and others have called on HMRC to review the aims and use of PPR before the planned cut to the final exemption period.  

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In some ways, the influence that the language of the PPR rules might have on our constructing a mental image of a Miss Doolittle may take us back to thoughts of Alice faced with mastering the language of Humpty Dumpty.

The Finance Bill was never laid before Parliament. It will be interesting to see how the next administration puts these proposals back together again.

William Hancock is a partner in the tax and estate planning team at Collyer Bristow




Please answer the six multiple choice questions below in order to bank your CPD. Multiple attempts are available until all questions are correctly answered.

  1. Why are off plan purchases popular right now?

  2. Why did HMRC decide that the gain on the sale of the apartment was only partially applicable?

  3. How is a period of ownership of a dwelling usually determined?

  4. Principal Property Relief applies when the property has been the owner's main residence throughout the period of ownership, true or false?

  5. What is PPR flipping?

  6. CGT was applicable in Mr Higgins case, because the ownership of the property started from the time he completed the purchase. True or false?

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  • Explain how Principal Private Residence relief works
  • Describe what happened in the case of Mr Higgins
  • Describe how PPR flipping works

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