Main residence exemption - when does the period of ownership start?
The Court of Appeal decision in Higgins and HMRC [2019] EWCA Civ 1860 restored a common sense approach to the CGT main residence exemption. The court ruled that residential property ownership starts when the purchase is completed. This is important because it is generally only possible for a purchaser to commence occupation from the date of completion, not exchange of contracts.
Mr Higgins had contracted to purchase off plan a flat in St Pancras station in London in 2006. At that point the development work had not commence...