Private Residence Relief – The Acid Tests

As a number of cases have shown, obtaining PRR is not as straightforward as it seems. The starting point for any private residence relief (PRR) claim is that the property must have been the taxpayer's home. It is not enough to say, "It was the only property I owned at the time".

Over the past couple of years, a number of tax tribunal cases have focused on the quality of residence, rather than the quantity (time spent). A consistent theme in these cases is the evidence available to support a taxpayer's claim of occupying a property as a home. This includes, for example, utility bills, council tax, postal arrangements and the voters' list.

Example cases

Taxpayer produces letter from HMRC as evidence