Corporation Tax Act 2010 section 67A

EEA furnished holiday letting business treated as a trade

Section 67A provides that a company's EEA furnished holiday lettings business is treated as a separate trade for corporation tax loss relief purposes, mirroring the treatment given to UK furnished holiday lettings under section 65.

• Where a company commercially lets furnished holiday accommodation in the EEA as part of its overseas property business, all such lettings are grouped together and treated as a single trade separate from the rest of the overseas property business.
• The profits and losses of this deemed trade are dealt with under the trading loss relief rules in Chapter 2 (sections 37 to 44, 45A to 45H, and 48 to 54), rather than the property loss rules, although the reference to losses "beginning before 1 April 2017" in section 45(1) is disregarded.
• The remaining overseas property business (excluding the EEA furnished holiday lettings) continues to be subject to the normal property loss rules under sections 66 and 67.
• Where only part of a property qualifies as furnished holiday accommodation, a fair and reasonable apportionment must be made to identify what falls within the deemed trade.