Bell and another v and Revenue and Customs Commissioners

Capital gains tax – Disposal of assets. A house built on a farm that the taxpayers had sold had not been an asset which had been 'used, and used only, for the purposes of the trade throughout the period of ownership' for the purposes of roll-over relief pursuant to s 152 of the Taxation of Chargeable Gains Act 1992. Consequently, that house could not constitute a 'qualifying asset' for the purposes of s 152 with the result that roll-over relief was not due and the Revenue and Customs Commissioners' assessments in relation to capital gains tax had been correct. Accordingly, the First-tier Tribunal (Tax Chamber) dismissed the taxpayers' appeal against those assessments.

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