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My client and her former husband moved from the UK to France in 1985 at which time they sold their only UK property and ceased to be UK tax resident.

In 2000 they jointly acquired an investment property in France with a sitting tenant. The couple divorced in 2005 and the investment property was transferred to my client as part of the divorce settlement. In 2006 she moved permanently to the UK. In 2019 the sitting tenant died. My client has now exchanged contracts to sell the property with a completion date of January 2020. At no point has my client lived in the property so there would appear to be no entitlement to the only or main residence exemption.

We have engaged French tax advisers in relation to the French...