Lee Sharpe looks at a recent Scottish capital gains tax (CGT) case involving the disposal of a dwelling within the grounds of a larger main residence.
Given how many tax cases have been heard over the years regarding the relief from capital gains tax (CGT) in respect of one’s only or main residence (referred to in this article as principal private residence (PPR) relief), it may surprise some readers to find that the provisions involved cover only three principal sections and a handful of pages of the relevant legislation (TCGA 1992, ss 222-224), although there are further sections dealing with dependent relatives, divorce, etc.).
The recent case Whyte v HMRC  UKFTT 0270 (TC) and the now-infamous Bunny Hall (nothing to do with rabbits) required a judgment spread over 135 pages. In stark contrast, this month&rsquo