New queries, issue 4580

Conversion time

Main residence relief on the conversion of a water tower to a residential property.

In 1997 my client purchased a disused Victorian water tower on the roof of which some telecom operators had installed antennae for which they paid a charge.

Six years later the telecom antennae were relocated to a temporary mast within the curtilage of the property and work started to convert the building into a single residential dwelling. When the conversion was completed a year later the building became the owner’s only or main residence. When the telecom operators replaced their antennae after the work was completed they did not have exclusive use so there is no main residence restriction.

Is time-apportionment the only method over the whole period of ownership by which the gain on the disposal is apportioned under TCGA 1992 Sch 4ZZC para 4...