Malcolm Finney highlights the conditions for private residence relief post-death.
Private residence relief (PPR) refers to a relief from a charge to capital gains tax (CGT) with respect to any gain which arises on a disposal of, or an interest in, a dwelling-house which during the period of ownership has been the person’s only or main residence (TCGA 1992, ss 222, 223).
The relief is available to individuals, trustees (TCGA 1992, s 225) and, perhaps surprisingly, personal representatives (PRs) (TCGA 1992, s 225A).
Death and CGT
For CGT purposes, at the date of death, the value of the residence (and other estate assets) is uplifted to market value without any resultant CGT charge (because the deceased is not treated as having made any disposals on death [TCGA 1992, s 62]).
However, the PRs during administration of the deceased;
