Jennifer Adams considers the importance of 'period of ownership' and 'occupation' in relation to a capital gains tax principal private residence relief claim.
Principal private residence (PPR) relief is one of the most important and familiar of reliefs against a capital gains tax (CGT) charge on the sale of a residence.
However, as is often the case with tax matters, this relief is not straightforward and comes with a set of conditions.
Lacking definitions
The relevant section of the Taxation of Chargeable Gains Act (TCGA) 1992 is s 222(1)(a), where PPR relief exempts a capital gain arising on a disposal of, or of an interest in:
‘(a) a dwelling house or part of a dwelling house which is, or has at any time in his period of ownership, been his only or main residence; or
(b) land which he has for his
