Averaging election

Business consisted mainly of making or holding investments

Appellant permitted to give oral evidence

Relevant business property

Business property relief, deceased's share of property

Capital allowances

EEA furnished holiday lettings

Generally

Giving effect to allowances and charges

Plant and machinery, use for other purposes

Qualifying activities

Qualifying activity

Capital gains tax

Chargeable gains

Qualifying loans

Reliefs available

Commercial letting

Commercial letting, meaning

Conditions not achieved despite genuine intention to do so

Conditions to be satisfied

Corporation tax

Averaging election

Capital allowances

Commercial letting

Commercial letting of, meaning

Conditions not achieved despite genuine intention to do so

EEA furnished holiday lettings business

EEA lettings

Furnished holiday accommodation, meaning

Generally

Loss relief

Losses

Non-resident landlords, deduction at source

Overview

Profits

Qualifying holiday accommodation, meaning

Relevant period, meaning

Rental income v trade profits

Separate calculations and apportionments

Trade or treated as a trade

Under-used, averaging elections

Corporation tax relief

EEA furnished holiday lettings business

Capital allowances

Chargeable gains

Generally

Loss relief

Pension purposes, relevant UK earnings

Treated as trade

EEA lettings

Generally

Giving effect to allowances and charges

Qualifying activities

Furnished holiday accommodation, meaning

Generally

History

Income tax relief

Inheritance tax business property relief

Limit on reliefs

Loss relief

Loss relief, commercial basis of letting

Losses

EEA furnished holiday lettings business

Generally

Pension income

Plant and machinery allowances

Profits and losses, treatment

Property business loss relief

Qualifying holiday accommodation

Qualifying loans

Relevant period, meaning

Relevant UK earnings

Relevant UK earnings for pension purposes

Relevant UK individual

Self-employment

Separate profit calculations and apportionment

Special tax rules

Substantial shareholdings, exemption for companies

Tax planning

Treated as trade, loss relief

Under-used

Averaging elections

Letting condition not met

VAT/GST