The purchase of a residential property, its demolition, the building of a new residence and its eventual sale did not amount to a venture in the nature of trade, and capital gains tax principle private residence relief was available in respect of its disposal. 

Summary 

The purchase of a residential property, its demolition, the building of a new residence and its eventual sale did not amount to a venture in the nature of trade, and capital gains tax (CGT) principle private residence (PPR) relief was available in respect of its disposal. 

Background 

The appellants owned a house (HP) in Holland Park. On 15 September 2010, they purchased another house (BS) in Chelsea for £9,750,000. Immediately after contracts were exchanged for BS in June 2010, the appellants met with architects and designers to explore how to renovate BS. An agreement was entered into with a specialist