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C Simpson v HMRC

In C Simpson v HMRC [2019] UKFTT 704 (21 November 2019) the FTT found that principal private residence (PPR) relief did not apply to the sale of a flat. 

Ms Simpson had made a gain on the disposal of a flat at Earl’s Court Square and the issue was whether PPR applied. HMRC’s case was that Ms Simpson was not entitled to claim PPR relief because she had never occupied the flat as a residence at all. In the alternative HMRC contended that if she occupied it as a residence the flat was not her main residence. In the further alternative HMRC submitted that if the flat was her main residence PPR relief was not applicable because she had acquired it wholly or partly for the purpose of realising a gain from the disposal of it. 

Ms Simpson had bought a flat at Coleherne...

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