The taxpayer’s period of ownership of an apartment for private residence relief purposes commenced at the date of the contract to acquire the lease of the apartment and ended at the date of the agreement to sell, which were also the dates of acquisition and disposal for capital gains tax (CGT) purposes.
Background
On 2 October 2006, the taxpayer entered into a contract to lease an apartment. The apartment did not exist in 2006; the area which was to become the apartment was a space in a tower.
