Out of Africa

We have been asked to act for a new client who has been living and working abroad for more than 10 years. He is domiciled in the UK but non-resident. He and his wife own the house they live in abroad and it is their main residence.

In 2010 they purchased an investment property in the UK with a view to living there on their return. A UK self-assessment tax return is filed by the husband each year with the rental income disclosed. The couple plan to return to the UK this December and live in the UK property.

We presume that at some point in the future they may start a family and move from this property to a larger one. In that event we are wondering whether capital gains tax main residence lettings relief would be available for the period when they...