Regardless of the need to achieve the qualifying day count limits as set out by the legislation, there is a first stage test that the letting must be commercial. The meaning of commercial letting of furnished holiday accommodation is defined in ITTOIA 2005, s. 323 for income tax purposes and CTA 2009, s. 265 for corporation tax purposes. The wording in each case is virtually identical. The requirement is that the letting must be commercial and with a view to the realisation of profits.
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