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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Private residence relief: permitted area: no agreement: Tribunal hearing

To present a permitted area case before the Tribunal close liaison with the VOA on the preparation of his or her evidence is vital. Depending on the requirements of the particular case the VOA may be able to give evidence on the following,


  • The size, character and environment of the dwelling house
  • The area and type of land held with the dwelling house
  • The planning history of the property
  • The history of acquisition of different parts of the property and of any disposals
  • The history of developments and any other changes in the neighbourhood of the property.


  • An opinion as to the location and area of the garden or grounds which make up the permitted area
  • Reasons for rejecting the areas claimed by the taxpayer to be within the permitted area
  • Details of comparable properties which can be cited to support the Valuation Office Agency’s opinion
  • An opinion as to the correct method of carrying out any necessary apportionments, but see CG64899.