Furnished Holiday Let (FHL) Abolition
The Furnished Holiday Let (FHL) tax regime was ABOLISHED with effect from 6 April 2025 for Income Tax + CGT (individuals) + 1 April 2025 for Corporation Tax (companies). Announced in Spring Budget 2024 (Jeremy Hunt) + continued by Labour government, no transitional grace period on the main reliefs. Former FHL properties are now treated as ORDINARY RESIDENTIAL RENTAL income within Section 24 (mortgage interest restriction at 20% credit). **What's been lost permanently from April 2025**: full mortgage interest deduction (now restricted via Section 24); capital allowances on furniture + fixtures (replaced by Replacement of Domestic Items relief); BADR on disposal at 10%/14% (now 24% residential CGT rate); CGT Rollover Relief on reinvestment; Gift Holdover Relief; FHL profits counting as pension relevant earnings; income allocation flexibility between spouses (default 50/50; Form 17 required for unequal split). Anti-forestalling rule applies from 6 March 2024: contracts exchanged on or after that date with completion after 5 April 2025 (1 April for companies) are DENIED CGT holdover + rollover relief. BADR exception for ceased businesses: where FHL conditions were met + business ceased before 6 April 2025, BADR may still apply within the normal 3-year post-cessation window.
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What this relief is, in plain English
FHL abolition is one of the most significant changes to UK private property investment in recent years, removing a 40-year-old special tax regime that recognised holiday-letting as a TRADE for many tax purposes (rather than a property INVESTMENT). The change was politically driven by housing-supply concerns in tourist hotspots (Cornwall, the Lake District, coastal Scotland) where short-let conversions were perceived to be reducing local housing availability + affordability. The mechanics of FHL had been generous: full mortgage interest deduction (no Section 24); capital allowances on furniture + fittings (vs Replacement of Domestic Items relief for ordinary residential); BADR-eligible disposal at preferential CGT rates (10%/14%); CGT Rollover Relief allowing gain deferral on reinvestment; Gift Holdover Relief allowing transfer to family without immediate CGT; pension relevant earnings status; income allocation flexibility between spouses regardless of actual ownership split. The combined effect was to make short-let holiday property investment economically attractive even where the underlying rental yield wasn't competitive. From 6 April 2025 (1 April for Corporation Tax), all of these reliefs are lost. Former FHL owners face an economic reset: pre-tax holiday-let yields that previously supported attractive after-tax returns now face the same tax treatment as ordinary residential lets, but with higher operating costs (cleaning, marketing, management) + often higher mortgage rates. Many ex-FHL owners are reconsidering whether to continue with short-let operations, switch to long-term residential lets, or sell + redeploy capital. The 6 March 2024 anti-forestalling rule was specifically designed to prevent pre-emptive sales / transfers from accessing the old reliefs before formal abolition.
How it works
Effective abolition dates
**Individuals (Income Tax + CGT)**: 6 April 2025. From this date, former FHLs are treated as ordinary residential rental property, Section 24 applies, no capital allowances on new furniture, no BADR, no Rollover/Holdover relief, no pension relevant earnings status, default 50/50 income split. **Companies (Corporation Tax + CT on chargeable gains)**: 1 April 2025. **Anti-forestalling**: from 6 March 2024, contracts exchanged with completion post-abolition are restricted (specific to CGT holdover + rollover relief; BADR position more nuanced).
What's lost from abolition
**Mortgage interest deduction**: full deduction → 20% basic-rate Section 24 credit only. **Capital allowances**: 18% WDA / AIA on furniture + fittings → Replacement of Domestic Items relief (replacement only, no initial fit-out). **BADR on disposal**: 10%/14% → 24% residential CGT rate (60-100% effective CGT increase depending on gain). **CGT Rollover Relief**: deferred gain on reinvestment into qualifying assets → not available. **Gift Holdover Relief**: transferred gain to recipient without immediate CGT → not available. **Pension relevant earnings**: FHL profits counted → no longer count toward 100%-of-UK-earnings cap on personal pension contributions. **Spouse income flexibility**: profits allocated flexibly → default 50/50 (or actual beneficial ownership); Form 17 needed for unequal split.
Transitional rules
Existing capital allowance pools from pre-April-2025 FHL expenditure can continue to be written down under standard WDA rules, main pool 18% (reducing to 14% from April 2026); special rate pool 6%. No market value balancing adjustment when pools roll into main property business. New expenditure from 6 April 2025 uses Replacement of Domestic Items relief only. FHL losses carried forward at 5 April 2025 can be set off against the WIDER UK + overseas property business profits from 2025/26, no longer ring-fenced to FHL business alone. BADR EXCEPTION: where FHL conditions were met + the FHL business CEASED before 6 April 2025, BADR may still apply to disposals within the normal 3-year window post-cessation.
Anti-forestalling, connected-party transfers
From 6 March 2024, contracts of transfer exchanged on/after that date with completion AFTER 5 April 2025 (or 1 April for companies) are denied CGT Holdover relief + Rollover relief for transfers between CONNECTED PERSONS. The mechanic specifically targets family-trust restructurings + spouse-incorporation transfers attempted in the announcement-to-abolition window. BADR position more nuanced: standard CGT disposal date rules generally apply (date of contract for unconditional contracts) but tax-motivated structuring can be challenged.
Who qualifies
- Property that WAS an FHL pre-6 April 2025, now treated as ordinary residential rental property
- OR ceased FHL business pre-6 April 2025 with disposal within 3-year window for residual BADR access
- Anti-forestalling rules apply to contracts exchanged on/after 6 March 2024 with post-abolition completions between connected persons (CGT Holdover + Rollover relief denied)
- Transitional capital allowance pools preserved for pre-April-2025 expenditure under standard WDA mechanics
- FHL losses at 5 April 2025 can be set against wider property business profits from 2025/26 onwards
Interactions with other reliefs
Section 24 Mortgage Interest Restriction
Former FHLs are NOW subject to Section 24 from April 2025 → mortgage interest restricted to 20% basic-rate credit. Higher-rate landlords face the same 50% effective relief reduction that ordinary residential landlords have faced since 2020. Combined with BADR loss + capital allowance loss, the after-tax economics of leveraged short-let holiday property has substantially weakened.
Replacement of Domestic Items Relief
Replaces capital allowances on furniture / white goods / carpets / curtains for former FHLs from April 2025. Like-for-like replacement only, no initial fit-out cost relief. Disposal of FHL furniture (sale, scrap) doesn't generate the balancing adjustments that historically applied under capital allowances. The mechanic is less generous than capital allowances but matches the position of ordinary residential lets.
BADR (rate trajectory 10% → 14% → 18%)
FHL disposals previously accessed BADR at the prevailing rate. Pre-30 October 2024 disposals: 10% BADR. 30 Oct 2024 - 5 April 2025: 14% BADR. From 6 April 2025: NO BADR (FHL regime abolished). Exception: business-ceased pre-6 April 2025 → 3-year window for disposal at the rate applicable when disposal occurs (e.g. 14% if disposed in 2025/26 within 3 years of cessation). Strategic note: many FHL owners accelerated disposals to pre-April-2025 to access 14% BADR rate; post-abolition disposals face 24% residential CGT rate (or 28% if part of higher-income year).
Pension Annual Allowance (100%-of-UK-earnings cap)
FHL profits previously counted as UK earnings for the 100%-of-earnings cap on personal pension contributions, useful for landlord-only individuals wanting to contribute to pensions. From April 2025, ex-FHL profits are no longer relevant earnings → cap reduces accordingly. Pure landlord investors with no other earnings have lost a significant pension contribution capacity. Mitigation: keep a side-hustle generating UK earnings + use Ltd Co employer pension contributions (no earnings cap).
Common mistakes + audit triggers
- Treating post-April-2025 ex-FHL income under pre-abolition rules (mortgage interest deductible, capital allowances on furniture), all gone
- Assuming BADR still available on disposal of ex-FHL property after April 2025 (only if business ceased pre-abolition + within 3-year window)
- Acquiring new furniture in 2025/26 + claiming capital allowances (no longer available; Replacement of Domestic Items only, and only for replacement)
- Transferring FHL to spouse / family / Ltd Co between 6 March 2024 + 5 April 2025 without considering anti-forestalling impact on Holdover/Rollover relief
- Continuing 50/50 income allocation between spouses by default when beneficial ownership is unequal, Form 17 declaration needed
- Assuming FHL profits still count as pension relevant earnings (they don't from April 2025, affects 100%-of-earnings pension contribution cap)
- Not modeling the combined Section 24 + capital allowance loss + BADR loss + Rollover loss impact on after-tax FHL economics (the cumulative cost is often substantial)
- Forgetting that pre-April-2025 capital allowance pools continue under standard WDA (preserved by transitional rules), not all FHL allowances lost retroactively
Worked example
Eileen + Niamh, Edinburgh - Edinburgh couple with FHL cottage in Pitlochry, comparing pre + post April 2025 tax position (2024/25 vs 2025/26 comparison)
Eileen + Niamh (jointly own, 50/50) have a holiday cottage in Pitlochry (Scotland) that operated as FHL through 2024/25 + meets the FHL conditions (140+ days available, 105+ days actually let, 31-day max single occupancy). 2024/25 figures: gross rental £24,000; expenses (cleaning, maintenance, management, insurance) £8,000; mortgage interest £6,500; £2,000 new furniture (Year 1 of FHL claim). 2025/26 projection (post-abolition): same income/cost structure but tax position changes.
Calculation: **2024/25, FHL regime applies (Income Tax + CGT):** Gross rent £24,000 Less: Cleaning + maintenance + management + insurance £8,000 Less: Mortgage interest £6,500 (full deduction, FHL outside Section 24) Less: AIA on £2,000 furniture (100% in year 1) £2,000 **FHL taxable profit: £7,500 (£3,750 each spouse via 50/50 split)** Eileen + Niamh both basic-rate taxpayers from other income. Their FHL income £3,750 each is within basic rate. Tax per spouse: 20% × £3,750 = £750. **Combined household tax on FHL 2024/25: £1,500.** **2025/26, Post-abolition (Section 24 + no AIA on new furniture):** Gross rent £24,000 Less: Cleaning + maintenance + management + insurance £8,000 (Mortgage interest £6,500 NOT deductible, Section 24 applies) (£2,000 new furniture, assume actual replacement of existing furniture, so Replacement of Domestic Items relief applies: £2,000 deductible) **Property profit BEFORE finance costs: £14,000 (£7,000 each spouse 50/50 split)** Eileen + Niamh tax on £7,000 each at basic rate 20%: £1,400 each = £2,800 combined. Less Section 24 credit: 20% × £6,500 = £1,300 (£650 each). **Combined household tax 2025/26: £2,800 - £1,300 = £1,500.** **Wait, basic-rate taxpayers face NO Section 24 net change.** For basic-rate taxpayers, the Section 24 mechanic (20% credit) is mathematically equivalent to deduction at 20%. Eileen + Niamh face NO INCOME TAX increase from Section 24 itself. **HOWEVER, the abolition still costs them:** - Capital allowances on furniture: pre-abolition £2,000 AIA fully deductible at investment; post-abolition only replacements deductible (not initial purchases or upgrades). If they buy NEW furniture (additional, not replacement) post-April 2025, that's £2,000 of capital expenditure with no deduction available. Lost relief on new furniture: £2,000 × 20% = £400/year if they regularly add new items. **Significantly larger impact on DISPOSAL:** When they eventually sell the cottage: - Pre-abolition disposal (e.g. early 2025/26 if BADR exception applies due to business cessation): BADR at 14% on gain. - Post-abolition disposal: standard residential CGT rate 24% (assuming higher CGT band), 71% increase in CGT effective rate. On a £150,000 gain (cottage bought for £200k, sold for £350k): - Pre-abolition with BADR: £150,000 × 14% = £21,000 CGT each spouse (split 50/50, £10,500 each). Combined household: £21,000. - Post-abolition without BADR: £150,000 × 24% = £36,000 CGT each spouse split... wait, the £150k gain is the COMBINED gain. Each spouse's share is £75,000 gain. Each spouse's CGT at 24% post-abolition: £75,000 × 24% = £18,000. Combined household: £36,000. - **Disposal-time additional CGT: £36,000 - £21,000 = £15,000 once-off cost** (if BADR available pre-abolition). **Higher-rate-taxpayer FHL owner scenario (illustrative):** For a higher-rate-taxpayer FHL owner, Section 24's restriction on mortgage interest deduction WOULD bite, 50% effective relief reduction × £6,500 mortgage interest = £3,250/year additional income tax post-abolition. Combined with capital allowance loss + BADR loss on disposal, total cost over 10-year hold + sale could easily be £30,000-£50,000 per property. **Strategic options for Eileen + Niamh:** A) **Continue as ordinary residential rental** (long-term let): switch to 6-month assured shorthold tenancy. Lower gross yield but lower management cost + same tax position. May make sense in Pitlochry's mixed-economy rental market. B) **Continue as holiday let (short-let)** without FHL tax status: same Section 24 mechanics as ordinary residential, but higher gross yields if location supports. Higher operating costs (cleaning, marketing). Net yield analysis needed. C) **Sell**: pre-cessation BADR available within 3-year window. If they had ceased FHL business pre-6 April 2025, they could sell at 14% BADR within 3 years. Worth £15,000+ at sale. D) **Transfer to Ltd Co**: would eliminate Section 24 but trigger SDLT + CGT. For a £350k property, SDLT ~£20k + CGT ~£21k = £41k one-off cost. Annual mortgage-interest-saving for basic-rate owners = nil (no Section 24 net impact). Not worthwhile for this profile.
Statute reference: Finance Act 2025 + Spring Budget 2024 (announcement) Abolition of FHL regime, see various amendments to ITTOIA 2005, CTA 2010, TCGA 1992. HMRC manual: PIM4100 (post-abolition replacement guidance).
Frequently asked questions
What happens if I miss the Self Assessment deadline?+
Do I need an accountant or can I file Self Assessment myself?+
How do payments on account work?+
I have a holiday cottage that was FHL, what do I lose from April 2025?+
I exchanged contracts to sell my FHL in February 2025 but completion is July 2025, can I claim BADR?+
Can I still claim capital allowances on FHL furniture I bought before April 2025?+
Is it worth continuing as a holiday let or should I switch to long-term residential letting?+
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