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Business Risk Services
Our Business Risk Services team deliver practical and pragmatic solutions that support clients in growing and protecting the inherent value of their businesses.
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Corporate Finance and Deal Advisory
We offer a dedicated team of experienced individuals with a focus on successfully executing transactions for corporates and financial institutions. We offer an integrated approach, with our corporate finance specialists working seamlessly with tax and other specialists to ensure that every angle is covered.
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Economic Advisory
Our all-island Economics Advisory team combines expertise in economics and business with a wealth of experience across the public and private sectors.
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Forensic Accounting
We have a different way of doing business by delivering real insight through a combination of technical rigour, commercial experience and intuitive judgment. We take pride in delivering responsive and tailored solutions to all our clients, capitalising on the wealth of experience housed within our Belfast and wider Forensics team
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People and Change Consulting
The Grant Thornton People & Change Consulting practice works with clients on these issues as well as on all aspects of how they attract, retain, engage develop, deploy and lead their people.
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Restructuring
We work with a wide variety of clients and stakeholders such as high street banks, private equity funds, directors, government agencies and creditors to implement solutions which provide the best possible outcomes.
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Technology Consulting
Motivating and assisting our clients to pursue, maintain and secure the benefits of digital solutions is at the core of our Digital Transformation teams' agenda and goals. We work with business leaders to deliver efficient digital strategies and operating models that provide new or enhanced capabilities.
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Corporate and International Tax
Northern Ireland businesses face further challenges as they operate in the only part of the UK that has a land border with a country offering a lower tax rate.
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Employer Solutions
Our team specialises in remuneration and incentive planning and works closely with employers, shareholders and employees to ensure that business strategies are aligned and goals achieved in the most tax efficient, cost-effective manner.
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Entrepreneur and Private Client Taxes
Our team of experienced advisors are on hand to guide you through any decision or transaction ranging from the establishment of new business ventures, to realising value on exit, to succession planning and providing for loved ones.
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Global Mobility Services
Grant Thornton Ireland offer a different approach to managing global mobility. We have brought together specialists from our tax, global payroll, people and change and financial accounting teams across Ireland and Northern Ireland, while drawing on the knowledge and insights of our global network of over 143 offices of mobility professionals to provide you with a holistic approach to managing global mobility.
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Outsourced Payroll
Our outsourced service provides valued service to over 150 separate PAYE schemes. These ranging from 1 to 1000 employees, working for micro, SME and global employers. The service is supported by the integrated network of tax and global mobility teams and the wider Grant Thornton network delivering a seamless service. Experienced staff deliver a personal service built around your business needs.
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Tax Disputes and Investigations
Our Tax Disputes and Investigation team is made up of tax experts and former HMRC investigators who have years of experience in dealing with a variety of tax investigations. Our expertise and insight can guide you through all interactions, keeping your cost at a minimum while allowing you to continue with the day to day running of your business.
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VAT and Indirect Taxes
At Grant Thornton (NI) LLP, our team helps Northern Ireland businesses manage their UK and global indirect tax risks which, as transactional taxes, can quickly become big liabilities.
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CGT can be levied on residential property gains at rates of 18% or 24%, depending on income levels, and any tax arising will be payable within 60 days of the sale. However, if the property sold is your main residence then a relief called Private Residence Relief (‘PRR’) may apply to exempt all (or part) of this gain from tax.
For these purposes, the property will be a dwelling house and will include adjoining buildings, such as garages. It will also include land surrounding the house, provided that this land does not exceed 0.5 hectares. HMRC may allow relief on a larger area of surrounding land if they are satisfied that the land is required for the ‘enjoyment’ of the property.
Where a property is an individual’s main residence, PRR can exempt part or all of the taxable gain. Periods of absence from the property can restrict the relief, resulting in a partial taxable gain. HMRC will allow some periods of absence to be ignored and these are referred to as period of ‘deemed occupation’; however the individual must have physically occupied the property before and after such period of absence.
The below occasions are where a period of absence can be treated as a period of deemed occupation:
| Length of Absence Allowed | Reason for Absence |
|---|---|
| Two Years | If at the beginning of ownership, the individual is prevented from immediately occupying the property due to construction, renovation or redecoration |
| Unlimited | Working outside of the UK |
| Four Years | Working elsewhere in the UK |
| Three Years | Any reason |
The last nine months of ownership will also qualify as a period of deemed occupation. The above deemed occupation periods can apply cumulatively, as long as the individual returns to the property.
HMRC may challenge the relief where they doubt that the individual lived at the property throughout the period of ownership. It is vital that the individual can prove that they actually lived in the home. There have been numerous cases where HMRC have challenged PRR. In the most recent case, Patwary v HMRC, HMRC assessed items such as the address on the electoral roll, utility bills, employment payslips and banking details to determine if individuals had indeed lived in the property which they claimed to be their home. HMRC may deny the relief where the residency ‘lacked permanence’ i.e. where the individual did not treat the property as their home.
If an individual has multiple homes in which they reside, they must nominate which home is to be their main residence. They must make this election within two years of acquiring the second home. If they cease to actually live in the nominated property, the election will lapse and this property will not qualify for relief. This nomination can be changed at any time.
Where a couple is married or in a civil partnership, the couple can only have one main residence. If both parties had their own homes prior to marriage, they should make the above election to nominate which home is their primary residence. If the other property is later sold then a gain could arise in respect of the period of ownership during which the other property was not occupied as a main residence.
Individuals who repeatedly purchase properties to renovate and sell are unlikely to be eligible for the relief, even where they have resided in the property. Instead, these sales could be charged at tax rates up to 47% because HMRC may argue that the individual is carrying on a trade of buying and selling property. HMRC will take this view where a property was purchased with the intention to sell and realise a profit on sale.
In summary, PRR will only apply to the sale of a property which has been lived in as a home, and where evidence shows there was some degree of permanence or continuity. In the absence of the relief, any gain would be charged at rates of either 18% or 24%. The tax would be due within 60 days of the sale, and the sale must be reported to HMRC via an online property return.