CG64945 - Private residence relief: ownership period: applying kink test


An individual bought house G in June 1979 for £15,000. She occupied it as her only residence until 1 May 1985 when she bought a second residence, house H. She nominated house H as her main residence within the time allowed by TCGA92/S222 (5), see CG64495. She sold house G on 1 October 1992 for £130,000. She has not made an election under TCGA92/S35 (5) but it is agreed that the value of house G at 31 March 1982 was £30,000.

The gain on house G is computed as follows.


  £
 Disposal proceeds130,000
lessValue at 31 March 198230,000
 Unindexed Gain100,000
lessIndexation 30,000 x 0.76122,830
 Net Gain77,170

Gain on historic cost


  £
 Disposal proceeds130,000
lessCost15,000
 Unindexed Gain115,000
lessIndexation 30,000 x 0.76122,830
 Net Gain92,170

The result of the `kink test', see CG16730+, is that the gain of £77,170 is the gain from which private residence relief will be deducted.

Private residence relief

For either computation the period of ownership for the purpose of computing relief is treated as beginning at 31 March 1982. So the relief will be


  • Period of ownership 31.3.82 - 1.10.92 = 126 months
  • Period of only or main residence 31.3.82 - 1.5.85 = 37 months
  • Final period allowed by Section 223(2) = 36 months

The relief is37 + 36x 77,170=44,710
126

The chargeable gain will be £32,460 before annual exempt amount.

NOTE. If a taxpayer is within the charge to Capital Gains Tax, neither indexation allowance nor taper relief apply to disposals of assets on or after 6 April 2008. Previously indexation allowance had been frozen at April 1998. For indexation allowance see CG17207+ and for taper relief see CG17895+.