It remains to be asked, however, whether the rule that there may be only one joint residence is appropriate in the era of independent taxation of married couples which began in 1990: private residence relief is now the only area of CGT where a couple are treated less favourably after marriage than they would be if they had lived together unmarried and not in a civil partnership (see FA 1988, s. 104(1)). The continuation of TCGA 1992, s. 222(6) may have political expediency (since couples with more than one home tend to be relatively wealthy and might be regarded as undeserving of any special treatment) but in logical terms it is now an anachronism.



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