Corporation Tax Act 2010 section 65

UK furnished holiday lettings business treated as trade

Section 65 provides that a company's UK furnished holiday lettings business is treated as a single trade for loss relief purposes, with specific modifications to the usual trade loss relief rules.

• A UK furnished holiday lettings business is treated as a single trade, with all qualifying commercial lettings of furnished holiday accommodation forming part of that trade, and profits charged to corporation tax accordingly.
• The usual UK property business loss relief rules (sections 62 to 64) apply to the remainder of the company's UK property business as though the holiday lettings were excluded from it.
• Trade loss relief rules in Chapter 2 apply to the holiday lettings trade, but with significant restrictions: sideways relief against total profits (sections 37 to 44), extended carry-forward rules (sections 45A to 45H), and various special rules for farming and other specific activities (sections 48 to 54) are all disapplied.
• Where only part of a letting qualifies as furnished holiday accommodation, just and reasonable apportionments must be made to determine what falls within the deemed trade.