Corporation Tax Act 2009 section 269A

Capital allowances and loss relief: overseas property business

Section 269A requires companies with an overseas property business that includes EEA furnished holiday lettings to split their calculations into two separate parts for the purposes of capital allowances and loss relief.

• Where a company's overseas property business includes EEA furnished holiday lettings, the profits and losses of those lettings must be calculated separately from the rest of the overseas property business.
• The business is split into two parts: the "EEA furnished holiday lettings part" (commercial letting of furnished holiday accommodation in one or more EEA states) and the "other part" (all remaining overseas property transactions).
• This separate calculation is required whenever capital allowances provisions or loss relief provisions apply to either part of the business.
• Where only part of a property is used as holiday accommodation, a reasonable apportionment must be made between the two parts.