The disposal of three residential properties in three consecutive tax years did not attract principal private residence relief as the taxpayer’s occupation of the properties did not have the necessary degree of permanence, continuity or expectation of continuity on the balance of probabilities.

Summary

The disposal of three residential properties in three consecutive tax years did not attract principal private residence relief as the taxpayer’s occupation of the properties did not have the necessary degree of permanence, continuity or expectation of continuity on the balance of probabilities.

Background

During the period 2013 to 2015 the appellant bought and sold at least five properties, three of which (‘CL’, ‘MC’, and ‘FC’) were solely owned; the other two properties were jointly owned.

The appellant purchased CL on 28 March 2013 for £125,000;