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HMRC Tax AppealsUnited Kingdom
Free CGT 60-Day Property Return Letter Template
A CGT 60-day property return is the mandatory route for reporting and paying Capital Gains Tax on a chargeable disposal of UK residential property in the United Kingdom. Use our free UK template as a companion letter to the HMRC CGT on UK Property Service (PPDCGT) — covering the gain computation, the 18% basic and 24% higher residential rate split, the £3,000 Annual Exempt Amount for 2026/27, the Private Residence Relief claim under TCGA 1992 sections 222-223 and the reasonable excuse defence to any late filing penalty applying the Perrin v HMRC four-stage objective test.
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CGT 60-Day Property Return — Late Filing Reasonable Excuse
Return Submitted Via The HMRC CGT On UK Property Service (PPDCGT) · 26 May 2026
Andrew James Pemberton
12 Yarrow Mews, Bristol BS8 4GP
07700 900618
a.pemberton@email.co.uk
26 May 2026
Capital Gains Tax — HM Revenue and Customs
Capital Gains Tax, HM Revenue and Customs, BX9 1AS, United Kingdom
CGT ON UK PROPERTY — LATE 60-DAY RETURN — REASONABLE EXCUSE
PPDCGT Ref: XAPD00123456789 | UTR: 4455667788
Dear Sir or Madam,
This letter accompanies the Capital Gains Tax return for the disposal of 4 Ashdown Terrace, Bath BA2 5LJ on 9 April 2026, submitted via the HMRC CGT on UK Property Service (PPDCGT). The disposal is a chargeable disposal of UK residential property under the Taxation of Chargeable Gains Act 1992, within the 60-day reporting and payment regime in section 14 and Schedule 2 of the Finance Act 2019 (as amended by the Finance (No.2) Act 2021 to extend the deadline from 30 days to 60 days). The 60-day deadline applicable to this disposal was 8 June 2026. The return has been submitted after that deadline. This letter sets out the reasonable excuse defence under paragraph 23 of Schedule 55 to the Finance Act 2009, applying the four-stage objective test in Perrin v HMRC [2018] UKUT 0156 (TCC).
This letter accompanies the Capital Gains Tax return for the disposal of 4 Ashdown Terrace, Bath BA2 5LJ on 9 April 2026, submitted via the HMRC CGT on UK Property Service (PPDCGT). The disposal is a chargeable disposal of UK residential property under the Taxation of Chargeable Gains Act 1992, within the 60-day reporting and payment regime in section 14 and Schedule 2 of the Finance Act 2019 (as amended by the Finance (No.2) Act 2021 to extend the deadline from 30 days to 60 days). The 60-day deadline applicable to this disposal was 8 June 2026. The return has been submitted after that deadline. This letter sets out the reasonable excuse defence under paragraph 23 of Schedule 55 to the Finance Act 2009, applying the four-stage objective test in Perrin v HMRC [2018] UKUT 0156 (TCC).
1.
TAXPAYER IDENTIFICATION
Full name: Andrew James Pemberton
Unique Taxpayer Reference (UTR): 4455667788
National Insurance number: PR 33 22 11 C
Correspondence address: 12 Yarrow Mews, Bristol BS8 4GP
Telephone: 07700 900618
Email: a.pemberton@email.co.uk
Unique Taxpayer Reference (UTR): 4455667788
National Insurance number: PR 33 22 11 C
Correspondence address: 12 Yarrow Mews, Bristol BS8 4GP
Telephone: 07700 900618
Email: a.pemberton@email.co.uk
2.
PROPERTY AND DISPOSAL
Property address: 4 Ashdown Terrace, Bath BA2 5LJ
Acquisition date: 22 August 2014
Acquisition cost (base cost): £228,000
Disposal date (completion): 9 April 2026
Disposal proceeds: £415,000
Chargeable gain: £152,400
Tax year of disposal: 2026/27
CGT rate: 24% (higher-rate band — applies from 6 April 2024 onwards; previously 28%)
Annual Exempt Amount used: £3,000 (AEA £3,000 for 2026/27)
60-day reporting deadline: 8 June 2026
Acquisition date: 22 August 2014
Acquisition cost (base cost): £228,000
Disposal date (completion): 9 April 2026
Disposal proceeds: £415,000
Chargeable gain: £152,400
Tax year of disposal: 2026/27
CGT rate: 24% (higher-rate band — applies from 6 April 2024 onwards; previously 28%)
Annual Exempt Amount used: £3,000 (AEA £3,000 for 2026/27)
60-day reporting deadline: 8 June 2026
3.
BRIEF REASONABLE EXCUSE STATEMENT
I disagree with any late filing penalty for the 60-day CGT return relating to the disposal of 4 Ashdown Terrace, Bath on 9 April 2026. I was admitted to hospital on 22 April 2026 with a stroke and remained an inpatient until 19 May 2026, with a further three-week recovery period during which I was unable to access correspondence or operate the gov.uk Sign In service. The return was submitted on 24 May 2026, immediately upon my discharge and once I had access to my conveyancer's completion paperwork. Medical evidence is enclosed.
4.
DISPOSAL AND GAIN COMPUTATION WORKSHEET
The chargeable gain is computed by deducting the acquisition cost, allowable acquisition costs (legal fees, SDLT, surveyors' fees), enhancement / capital improvement expenditure and allowable disposal costs (estate agent's commission, conveyancing fees) from the disposal proceeds. Allowable capital losses (current year and brought forward) are then deducted, and the Annual Exempt Amount applied. The residual gain is taxed at 18% to the extent it falls within the basic-rate band and 24% to the extent it falls within the higher-rate band (residential property rates from 6 April 2024 onwards).
Disposal proceeds: £415,000
Acquisition cost: £228,000
Allowable acquisition costs (legal / SDLT / survey): £3,250
Enhancement / capital improvement expenditure: £18,500
Allowable disposal costs: £12,850
Annual Exempt Amount applied: £3,000 (AEA £3,000 for 2026/27)
Net chargeable gain: £152,400
The gain is computed as follows: disposal proceeds £415,000 less acquisition cost £228,000 less allowable acquisition costs £3,250 (SDLT, legal fees, survey) less enhancement expenditure £18,500 (loft conversion 2017) less allowable disposal costs £12,850 (estate agent commission 2.5%, conveyancing fees) = £152,400 gross gain. The property was not the only or main residence at any time during ownership (it was let throughout). No PRR applies. The Annual Exempt Amount of £3,000 for 2026/27 has been applied. The net chargeable gain is £149,400. As I am a higher-rate taxpayer, the 24% residential rate applies, giving CGT of £35,856 paid on account on 24 May 2026.
Disposal proceeds: £415,000
Acquisition cost: £228,000
Allowable acquisition costs (legal / SDLT / survey): £3,250
Enhancement / capital improvement expenditure: £18,500
Allowable disposal costs: £12,850
Annual Exempt Amount applied: £3,000 (AEA £3,000 for 2026/27)
Net chargeable gain: £152,400
The gain is computed as follows: disposal proceeds £415,000 less acquisition cost £228,000 less allowable acquisition costs £3,250 (SDLT, legal fees, survey) less enhancement expenditure £18,500 (loft conversion 2017) less allowable disposal costs £12,850 (estate agent commission 2.5%, conveyancing fees) = £152,400 gross gain. The property was not the only or main residence at any time during ownership (it was let throughout). No PRR applies. The Annual Exempt Amount of £3,000 for 2026/27 has been applied. The net chargeable gain is £149,400. As I am a higher-rate taxpayer, the 24% residential rate applies, giving CGT of £35,856 paid on account on 24 May 2026.
5.
PPDCGT SUBMISSION VIA THE HMRC CGT ON UK PROPERTY SERVICE
The return was submitted via the HMRC CGT on UK Property Service (the PPDCGT online service) accessed through the taxpayer's gov.uk Sign In account. The service generates a unique CGT property disposal reference and produces an estimated tax due figure for payment on account by the same 60-day deadline. The 60-day deadline runs from the date of completion of the disposal (not the date of exchange of contracts).
PPDCGT reference: XAPD00123456789
Submission date: 24 May 2026
Payment on account made: £35,856 on 24 May 2026
Statutory framework: section 14 and Schedule 2 of the Finance Act 2019 (as amended by the Finance (No.2) Act 2021)
PPDCGT reference: XAPD00123456789
Submission date: 24 May 2026
Payment on account made: £35,856 on 24 May 2026
Statutory framework: section 14 and Schedule 2 of the Finance Act 2019 (as amended by the Finance (No.2) Act 2021)
6.
LATE FILING PENALTY DEFENCE — PERRIN FOUR-STAGE TEST
Where a 60-day return is filed after the deadline, paragraph 23 of Schedule 55 to the Finance Act 2009 provides a defence to the late filing penalties where the taxpayer had a reasonable excuse for the failure. The Upper Tribunal in Perrin v HMRC [2018] UKUT 0156 (TCC) settled the four-stage objective test the decision-maker must apply:
Stage 1 — Facts asserted:
The disposal of 4 Ashdown Terrace, Bath completed on 9 April 2026 — at that date I was a higher-rate UK-resident individual taxpayer required to file a 60-day CGT property return through the HMRC CGT on UK Property Service. The 60-day deadline was 8 June 2026. On 22 April 2026 — 13 days into the 60-day window — I attended Bath Royal United Hospital with sudden onset of left-side weakness and slurred speech. I was admitted with a confirmed ischaemic stroke, transferred to the stroke unit and remained an inpatient until discharge on 19 May 2026. The discharge summary records that I was advised to avoid all work and stressful activity for at least three weeks following discharge and that I was unable to operate online services involving multi-factor authentication during that recovery period. My conveyancer held the completion paperwork during this entire time and was unable to deal with it without my involvement. I had no realistic capacity to submit the 60-day return between 22 April 2026 and 23 May 2026.
Stage 2 — Objective assessment: the facts above, viewed objectively, amount to a reasonable excuse for the failure to file the 60-day return within the statutory window.
Stage 3 — Date the reasonable excuse ceased: 23 May 2026.
Stage 4 — Remedy without unreasonable delay:
After being cleared on 23 May 2026 to resume normal activity, I took immediate action: I emailed my conveyancer the same evening, accessed the gov.uk Sign In service through my CGT property account the following morning (24 May 2026), submitted the 60-day return and made the payment on account of £35,856 the same day. The total elapsed time between the excuse ceasing and the failure being remedied was less than 36 hours. The objective Perrin test is satisfied — a reasonable person in the same circumstances, recovering from an acute stroke, could not have remedied the failure any faster.
First-time defaulter: the taxpayer has no prior 60-day return failures. The clean compliance history is relevant to proportionality and to the special reduction power in paragraph 16 of Schedule 55.
Stage 1 — Facts asserted:
The disposal of 4 Ashdown Terrace, Bath completed on 9 April 2026 — at that date I was a higher-rate UK-resident individual taxpayer required to file a 60-day CGT property return through the HMRC CGT on UK Property Service. The 60-day deadline was 8 June 2026. On 22 April 2026 — 13 days into the 60-day window — I attended Bath Royal United Hospital with sudden onset of left-side weakness and slurred speech. I was admitted with a confirmed ischaemic stroke, transferred to the stroke unit and remained an inpatient until discharge on 19 May 2026. The discharge summary records that I was advised to avoid all work and stressful activity for at least three weeks following discharge and that I was unable to operate online services involving multi-factor authentication during that recovery period. My conveyancer held the completion paperwork during this entire time and was unable to deal with it without my involvement. I had no realistic capacity to submit the 60-day return between 22 April 2026 and 23 May 2026.
Stage 2 — Objective assessment: the facts above, viewed objectively, amount to a reasonable excuse for the failure to file the 60-day return within the statutory window.
Stage 3 — Date the reasonable excuse ceased: 23 May 2026.
Stage 4 — Remedy without unreasonable delay:
After being cleared on 23 May 2026 to resume normal activity, I took immediate action: I emailed my conveyancer the same evening, accessed the gov.uk Sign In service through my CGT property account the following morning (24 May 2026), submitted the 60-day return and made the payment on account of £35,856 the same day. The total elapsed time between the excuse ceasing and the failure being remedied was less than 36 hours. The objective Perrin test is satisfied — a reasonable person in the same circumstances, recovering from an acute stroke, could not have remedied the failure any faster.
First-time defaulter: the taxpayer has no prior 60-day return failures. The clean compliance history is relevant to proportionality and to the special reduction power in paragraph 16 of Schedule 55.
7.
CONCLUSION
I respectfully ask HMRC to accept the reasonable excuse defence set out above and to cancel any late filing penalty issued in respect of the late submission of the 60-day return for the disposal of 4 Ashdown Terrace, Bath BA2 5LJ on 9 April 2026. The return has now been filed and the payment on account made. Where any tax-geared element remains in dispute, I rely on the special reduction power in paragraph 16 of Schedule 55 in the alternative. Please acknowledge receipt and notify me of any further information required.
YOURS FAITHFULLY,
Andrew James Pemberton
Taxpayer — 26 May 2026
Date: ____________________
TAXPAYER
Andrew James Pemberton
Date: ____________________
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What Is a CGT 60-Day Property Return?
The 60-day Capital Gains Tax return is the payment-on-account regime for UK residential property disposals introduced by section 14 and Schedule 2 of the Finance Act 2019 with effect from 6 April 2020. The original deadline was 30 days from the date of completion; the Finance (No.2) Act 2021 extended the window to 60 days for completions on or after 27 October 2021. The return and the corresponding payment on account of CGT are submitted via the HMRC CGT on UK Property Service (PPDCGT) accessed through the taxpayer's gov.uk Sign In account.
A return must be filed where a chargeable disposal of UK residential property produces a CGT liability — typically the sale of a buy-to-let property, a second home or any residence which is not fully covered by Private Residence Relief. The 60-day deadline runs from the date of COMPLETION of the disposal (not the date of exchange of contracts). UK-resident individual taxpayers do not need to file a 60-day return where no CGT is due — for example where Private Residence Relief covers the full gain, where the gain is fully sheltered by the Annual Exempt Amount or where allowable losses fully cover the gain.
For 2026/27, the Annual Exempt Amount is £3,000 (reduced from £6,000 for 2024/25 and £12,300 for 2023/24). The residential CGT rates are 18% in the basic-rate band and 24% in the higher-rate band — the 28% higher rate was reduced to 24% from 6 April 2024. Where the 60-day return is filed late, the late filing penalty regime in Finance Act 2009 Schedule 55 applies (£100 fixed; £10/day after 3 months up to £900; greater of £300 or 5% of tax due at 6 months and at 12 months). Paragraph 23 of Schedule 55 provides a reasonable excuse defence — the Upper Tribunal in Perrin v HMRC [2018] UKUT 0156 (TCC) settled the four-stage objective test the decision-maker must apply.
What's Covered in This Template
Our UK CGT 60-day property return companion letter records the gain computation, the rate split, the AEA used, any PRR or Lettings Relief claim and (where the return is late) the structured Perrin four-stage reasonable excuse defence.
Taxpayer Identification Block
Records the taxpayer's name, address, UTR (10-digit) and NI number — the data HMRC needs to match the CGT return to the taxpayer's record.
HMRC CGT Postal Address
Pre-fills the HMRC CGT correspondence address: Capital Gains Tax, HM Revenue and Customs, BX9 1AS, United Kingdom — the same code as Self Assessment correspondence.
Property + Disposal Details
Records the property address, the acquisition date and cost, the disposal date (completion) and the disposal proceeds — with the 60-day deadline auto-calculated from the date of completion.
Tax Year + Rate Selector (18% / 24%)
Tax year selector (2024/25, 2025/26, 2026/27) and CGT rate selector (18% basic band, 24% higher band — the residential rate post-6 April 2024). The AEA used is recorded separately.
Late Filing Switch
Switches the letter between (i) a companion letter for a return filed within the 60-day window and (ii) a reasonable excuse defence letter for a return filed late under FA 2009 Schedule 55.
Expert: Disposal & Gain Computation Worksheet
Detailed computation showing disposal proceeds; acquisition cost; allowable acquisition costs (SDLT, legal, survey); enhancement / capital improvement expenditure; allowable disposal costs; allowable capital losses; AEA applied; band split between 18% and 24% rates; total CGT due.
Expert: PPDCGT Submission Detail
Records the PPDCGT reference (CGT property disposal reference), the submission date, the payment on account made and the corresponding date — for HMRC's records and for any future reconciliation with the SA return.
Expert: Perrin Four-Stage Reasonable Excuse Defence
Where the return is late, the structured four-stage objective test from Perrin v HMRC [2018] UKUT 0156 (TCC) — facts asserted; objective assessment; date the excuse ceased; remedy without unreasonable delay.
Expert: Private Residence Relief Claim
PRR claim under TCGA 1992 sections 222-226 — full or partial relief, periods of occupation, deemed occupation periods (working abroad, working elsewhere in the UK up to 4 years, absence for any reason up to 3 years where the property is reoccupied) and the final 9 months of ownership rule under section 222(5).
Expert: Lettings Relief (Shared Occupation Only)
Lettings Relief claim under TCGA 1992 section 223B — restricted from 6 April 2020 to periods of shared occupation between the owner and the tenant. The relief is the lower of: the gain attributable to the let period; the PRR amount; and £40,000 (£80,000 for joint owners).
Single Signer — Taxpayer
The companion letter is signed by the taxpayer. No witness or notarisation is required for an HMRC CGT 60-day return.
How to File a CGT 60-Day Property Return
Follow these steps to file the CGT 60-day return and produce the supporting companion letter in a format HMRC accepts across the United Kingdom.
- 1
Check the 60-Day Deadline
The deadline runs from the date of COMPLETION of the disposal (not the date of exchange of contracts). The template auto-calculates the 60-day deadline once you enter the completion date.
- 2
Set Up the CGT on UK Property Account
Set up a Capital Gains Tax on UK Property account via your gov.uk Sign In. The account links to your existing personal tax account. You can authorise your tax adviser to file on your behalf.
- 3
Compute the Gain
Disposal proceeds less acquisition cost less allowable acquisition costs (SDLT, legal, survey) less enhancement / capital improvement expenditure less allowable disposal costs (estate agent, conveyancing). Apply any allowable capital losses (current year and brought forward) and the AEA for the tax year (£3,000 for 2026/27).
- 4
Apply the Rate Split
For UK residential property disposals from 6 April 2024 onwards, the rates are 18% in the basic-rate band and 24% in the higher-rate band. Before 6 April 2024 the higher rate was 28%. Where the gain straddles the basic rate band, the basic-rate portion is taxed at 18% and the higher-rate portion at 24%.
- 5
Apply Private Residence Relief (if any)
Sections 222-223 of TCGA 1992 give relief where the property has been the taxpayer's only or main residence. Section 222(5) gives relief for the final 9 months of ownership regardless of actual occupation, provided the property was the only or main residence at some point during ownership.
- 6
Apply Lettings Relief (if any)
TCGA 1992 section 223B was reformed from 6 April 2020 — Lettings Relief now applies only to periods of SHARED occupation between owner and tenant. The relief is the lower of: the gain attributable to the let period; the PRR amount; and £40,000 (£80,000 for joint owners).
- 7
Submit the Return via PPDCGT
Log into your gov.uk Sign In CGT property account, complete the online form (the PPDCGT) and pay the CGT on account. The service issues a CGT property disposal reference for your records.
- 8
Send the Companion Letter (Optional but Recommended)
Post the supporting computation letter to Capital Gains Tax, HM Revenue and Customs, BX9 1AS, United Kingdom. Quote your UTR and the PPDCGT reference. This is particularly important where PRR or Lettings Relief is claimed or where the return is late and a reasonable excuse defence is relied on.
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Legal Considerations — CGT 60-Day Property Return
The CGT 60-day reporting and payment regime is governed by the Finance Act 2019 (as amended) and the substantive provisions of the Taxation of Chargeable Gains Act 1992. The framework applies across the United Kingdom.
This template is for general information and does not constitute legal or tax advice. The Chartered Institute of Taxation and ACCA regulate practitioners advising on CGT. Where the disposal involves significant value, partial PRR computation, joint ownership or trust structures, formal advice from a chartered tax adviser or solicitor is strongly recommended. The First-tier Tribunal (Tax Chamber) has the final word on any disputed elements.
Reviewed for the United Kingdom
Statutory Framework — 60-Day Reporting
The 60-day reporting and payment regime is in section 14 and Schedule 2 of the Finance Act 2019. The regime applies to chargeable disposals of UK residential property by UK-resident individuals, trustees and personal representatives. The original 30-day deadline was extended to 60 days for completions on or after 27 October 2021 by the Finance (No.2) Act 2021. The return is filed and the payment on account made via the HMRC CGT on UK Property Service (PPDCGT).
Substantive CGT Framework
CGT on UK residential property is governed by the Taxation of Chargeable Gains Act 1992. The disposal computation is in section 38 (allowable expenditure) read with section 17 (consideration). Section 222 confers Private Residence Relief; section 223 governs the period of qualifying occupation; section 222(5) provides the final-9-months rule (reduced from 18 months on 6 April 2020). Section 223B governs Lettings Relief — restricted to shared occupation periods from 6 April 2020 by the Finance Act 2020.
2026/27 Rates and Allowances
The residential property CGT rates from 6 April 2024 onwards are 18% in the basic-rate band and 24% in the higher-rate band. The non-residential rates are 10% and 20%. The Annual Exempt Amount for 2026/27 is £3,000 (down from £6,000 for 2024/25 and £12,300 for 2023/24). Joint owners each have their own AEA. The AEA cannot be carried forward or back.
Late Filing Penalty Regime — FA 2009 Schedule 55
Where the 60-day return is filed late, the late filing penalty regime in Finance Act 2009 Schedule 55 applies — £100 fixed at day one (paragraph 3); £10 per day for up to 90 days after 3 months late (paragraph 4); the greater of £300 or 5% of the tax due at 6 months late (paragraph 5); the greater of £300 or 5% of the tax due at 12 months late (paragraph 6). Paragraph 23 provides the reasonable excuse defence; paragraph 16 provides the special reduction power.
Perrin v HMRC — Reasonable Excuse
The Upper Tribunal in Perrin v The Commissioners for HM Revenue and Customs [2018] UKUT 0156 (TCC) settled the four-stage objective test. The decision-maker must: (1) establish the facts the taxpayer asserts; (2) consider whether those facts viewed objectively amount to a reasonable excuse; (3) identify the date the reasonable excuse ceased; (4) decide whether the taxpayer remedied the failure without unreasonable delay. The test is objective — the taxpayer's beliefs and conduct are judged by reference to a reasonable person in the same circumstances.
Appeal Route
Where HMRC declines a reasonable excuse defence, the taxpayer can request an internal review under TMA 1970 section 49A. If the review remains adverse, the appeal goes to the First-tier Tribunal (Tax Chamber) via form T240 to PO Box 16972, Birmingham B16 6TZ. The 30-day FTT window runs from the date of the review conclusion letter or the original HMRC decision.
Frequently Asked Questions
Build Your CGT 60-Day Property Return
Produce a clear computation letter to support the HMRC CGT on UK Property Service submission. Whether the return is filed on time or late (with a Perrin reasonable excuse defence), the template covers the 18% / 24% rate split, the £3,000 AEA for 2026/27, the PRR claim under TCGA 1992 sections 222-223 and the Lettings Relief computation — sent to Capital Gains Tax, HM Revenue and Customs, BX9 1AS, United Kingdom.
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