In G Ives v HMRC [2023] UKFTT 968 (TC) (13 November 2023) the First-tier Tribunal (FTT) allowed the taxpayer’s appeal against closure notices which had treated repeated property transactions as trading ruling that the transactions were not trading and were exempt from CGT by virtue of principal private residence (PPR) relief.
The taxpayer purchased and sold three residential properties selling each one shortly before purchasing the next. Each property was sold at a substantial gain after significant improvements had been made. This included converting the first property from two flats into a single home. The second property was purchased with a part-completed renovation which the taxpayer finished. Throughout the period in which the purchases and sales were made the taxpayer owned a fourth residential property. This had briefly been the family home before the first purchase in dispute and had then been put on the market after...
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