In HMRC v G Lee and another [2023] UKUT 242 (TCC) (“the Lee case”) the provisions of the UK equivalent of s604 TCA 1997 (s222 Taxation of Capital Gains Act 1992) were considered by the Upper Tribunal in the context of residential land undergoing redevelopment. The facts relate to a house that has been lived in since completion of construction but where the land on which the house was built has been owned for longer than the existence of that house. The interpretation adopted by the Upper Tribunal (upholding the decision of the First-tier Tribunal in G Lee and anor v HMRC [2022] UKFTT 175 (TC)) suggests a different approach from Irish Revenue’s published guidance on the topic. (The Upper Tribunal decision was also considered by Stephen Ruane and Patrick Lawless in “Direct Cases: Decisions from the UK and European Courts”, Irish Tax Review, Issue No. 4, 2023).