For many owners, one of the main attractions of the special FHL rules is entitlement to business asset disposal relief (BADR) and a 10% CGT rate on the sale of a property. BADR is available (subject to certain conditions) to an FHL business conducted by a sole trader, a partnership or a company. Where a trust owns the properties, the activity would have to be undertaken by a beneficiary with an interest in possession in order to get the relief.

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