Taxation logo taxation mission text

Since 1927 the leading authority on tax law, practice and administration

ER run off

14 July 2009
Issue: 4214 / Categories: Forum & Feedback , FHL , Capital Gains
Entrepreneurs’ relief for furnished holiday letting properties is to be abolished from April 2010. Will this mean that the business is treated as having ceased such that relief continues to be available if the property is sold within the following three-year period?

My client has a furnished holiday letting property which he has owned for several years and which is currently standing at a substantial gain.

He has no intention of selling it in the near future but is aware that the favourable capital gains tax treatment – the availability of entrepreneurs’ relief (ER) giving an effective tax rate of 10% – is being taken away on 6 April 2010.

There is no time apportionment with ER; if you don’t qualify for it at the point of sale you don’t qualify at all. My client might consider selling but it’s possible that there will be a tax-driven glut in the market for holiday properties at that time because everyone will be thinking the same thing.

Presumably it is possible to transfer the property into a trust or a company in order to trigger the gain at the...

If you or your firm subscribes to, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.

back to top icon