A number of recent decisions at tax tribunals are likely to have an influence on the interpretation of capital gains tax (CGT). First, there is the long-awaited Court of Appeal decision in Higgins centering on the argument that the ‘period of ownership’ for private residence relief (PRR) purposes should be measured by reference to completion dates rather than dates of exchange of contracts.

The recent First Tier Tribunal (FTT) decision (Lloyd-Webber [2019] UKFTT 717 (TC)) cast doubt on the decision of the Upper Tribunal in Hardy v R & C Commrs [2016] BTC 514 on the treatment of contractual rights. Yet another tribunal in the Reneaux case considered the activities that amount to a ‘trade’ for entrepreneurs’ relief purposes.