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Is principal private residence relief available on the whole of the property?

Question:

I sold a property for £173,000 in the 2018/19 tax year. I acquired a one-third ownership of the property in 1985 with my mum and dad. The one-third of the property cost me £3,000. I lived in the property until 1988 when I moved out and lived in a new main residence. In 2007, my mum died and half of her share (one-sixth of the overall property) was given to me and the other half given to my dad. At this time the one-sixth was valued at £22,000. In 2011, my dad died and his 50% of the property was given to me. The 50% at this point was valued at £65,000. The property was then let until being sold in the 2018/19 tax year. With regard to principal private residence (PPR) relief and lettings relief, would this only be relevant on the one-third share I acquired in 1985? 

Arthur Weller replies: 
In HMRC’s Capital Gains manual at www.gov.uk/hmrc-internal-manuals/capital-gains-manual/cg64930 it states: 'Under TCGA92/S222(7) where different interests are held at different times, the period of ownership begins at the date of the first acquisition on which expenditure is incurred, which would have been deductible in computing any gain'. Presumably, when you lived in the house, you lived in the whole house. I do not know a definitive answer to your question, but I suggest that if claiming PPR relief on the gain on the whole house, you explain what you are doing in the white space in the tax return.
 

I sold a property for £173,000 in the 2018/19 tax year. I acquired a one-third ownership of the property in 1985 with my mum and dad. The one-third of the property cost me £3,000. I lived in the property until 1988 when I moved out

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This question was first printed in Tax Insider in March 2020.