There cannot be many tax reliefs with a wider application than Main Residence Relief. It is a venerable relief, having been a part of Capital Gains Tax since the tax’s introduction in the Finance Act of 1965, but it continues to trouble the Courts on a regular basis, not only in respect of recent amendments but also in respect of features which have been fundamental to the relief since its enactment 57 years ago.
It must, surely, not be uncommon for buyers of residential properties substantially to reconstruct them or to demolish the existing building and to build a replacement. Yet the application of Main Residence Relief in these circumstances is beset by uncertainties. Recently, in advising a client, we had cause to examine these uncertainties which we discuss in the latest issue of the Rudge Revenue Review, Issue XXX, which can be accessed here.