Readers’ forum: Holiday hotel

My client a non-UK company is considering an investment in Nights Inn an established UK chain of hotels which operates a large portfolio across the country. It is offering the public an investment opportunity of acquiring a room in a Manchester hotel it operates. The investor pays a capital sum for a 999-year lease of a room entitling them to the lion’s share of any revenue generated by stays in that particular room. The appeal is that my client will receive monthly income net of expenses and the hotel’s commission. I am confident that the room contains ‘sufficient furniture provided for normal occupation’ and that visitors are ‘entitled to use the furniture’ to quote HMRC’s guidance in HS253. I understand that there are unlikely to be ‘long stays’ of more than 31 days the room is marketed for at least 210 days...