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Direct disposals of residential property

Tax Planning: 2023/24

Edited by:
Mark McLaughlin
Publisher:
Bloomsbury Professional
Edition:
2023/24 edition
Publication Date:
March 2024
Law Stated At:
22 February 2024
Chapter 15: Non-resident CGT and UK land Meaning of residential property gain ‘…We agree with Judge McKeever that Lewis v Lady Rook (above) and Longson v Baker (above), Capital Gains Tax cases to which Mr Callard drew our attention, were of no real assistance. The CGT regime is different as Judge McKeever explained. The cases are simply illustrations of particular facts found as to what constituted grounds. Much the same point applies to HMRC’s SDLT’s Guidance, specifically SDLTM00365, SDLTM00390, SDLTM00440, SDLTM00445, SDLTM00450, SDLTM00455, SDLTM00460, SDLTM00465, SDLTM00470, SDLTM00475 and SDLTM00480, of which both parties are well aware and which are too lengthy to set out in this decision.’Meaning of a ‘dwelling’ ...

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