This would particularly affect those who spend the week in a city flat for work and weekends at a family home in the country. Council tax records indicate that there are more than 250,000 second homes in the UK.
The consultation follows changes, which begin today, halving the amount of time an individual has to sell a second home before capital gains tax is due. Previously, if a second property was declared a main residence at any time, there was no capital gains tax to pay for the final three years of ownership. This now falls to 18 months.
There are two options in the consultation documents. One would be based on a "balance of evidence" such as the address where a taxpayer's family lives, where post is sent and where a taxpayer is registered to vote.
The second is a fixed rule that identifies a person's main residence based on the time spent at the property.
Patricia Mock of Deloitte, the accountancy firm, said: "Frankly, the second test seems impractical. The first test on the balance of probabilities seems more straightforward, but that will still be difficult."
The changes are part of a consultation on how to make non-residents pay capital gains on homes in Britain, but the changes are likely to have a wide-ranging effect on British residents.
Those who spend more time in a flat could be forced to pay capital gains tax of up to 28pc on the sale of their family home.
A spokesman for HM Revenue & Customs said: "The changes in the election of private residence relief on an individual's main residence are proposals and we are seeking views on how best to implement this change.
"Apart from the final period, individuals currently receive the relief for only one property at a time even if they have more than one home, and this will not change."
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