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Clarification needed on policy intent regarding FHLs, says CIOT

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The CIOT has published its response to the consultation on the draft legislation to abolish the furnished holiday lettings (FHL) tax regime.

The key points raised in the response include:

  • clarification is needed on the policy intent regarding the tax status of furnished holiday lettings going forward to provide certainty and avoid costly disputes in relation to claims for trading status;
  • the draft legislation should clarify the position regarding business asset disposal relief (BADR) for disposals relating to pre-commencement FHL businesses, including whether there is a deemed cessation on 5 April 2025;
  • guidance is needed on the application of the 50:50 income splitting rules in ITA 2007, s 836 to former FHL properties owned jointly from 6 April 2025, and the ability to backdate section 837 elections is suggested;
  • confirmation is sought on various technical points, such as the treatment of the "relevant period" for new FHLs in 2024/25, eligibility for rollover relief on replacement assets acquired after 6 April 2025, and the ability to make section 198 capital allowance elections; and
  • suggestions include uprating the £1,000 small pools limit for capital allowances, evaluating the £3,600 basic pension contribution limit, and providing guidance on VAT, business rates, and other consequential impacts.
Issue: 1676
Categories: News
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