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Capital gains principle private residence relief is available not only on the sale of main residence but also on the sale of the garden that attaches to the main residence.
To qualify for relief the land must meet the following conditions on the date its sold:
As your client has lived in the house during the whole period of her ownership then private residence relief may be available on the disposal of the garden bearing in mind the points above. The legislation makes no reference to how the land is used during the period of ownership. Therefore the use of the land at any date other than the date of disposal is irrelevant. It is crucial therefore that your client continues to use the garden up to the date it is sold and that it is not for example fenced off in any way.