By Aidan Grant

A recent tax tribunal case has confirmed that an individual was liable to CGT on an off-plan property sale throughout their period of ownership, notwithstanding that part of the period included a time when the property had not yet been built.

This ruling confirms that private residence relief turns on occupancy and that, broadly speaking, purchasers will only qualify for PPR for those periods of actual occupation. This ruling is significant for those who buy offplan properties because it may be some years before the property is built and the new owners can move in.