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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Non-resident companies: exemptions: furnished holiday accommodation


For gains on disposals from 6 April 2012, trade assets also includes assets such as accommodation or an interest or right in accommodation, which is situated outside the UK where the accommodation has been furnished holiday accommodation for each relevant period.

A relevant period is:

the period of 12 months ending with the date of disposal


each of the two preceding periods of 12 months.

If the company has been the beneficial owner of the accommodation (or interest or right in accommodation) for a period longer than 36 months then relevant periods will be the 12 months up to the date of disposal and the preceding two periods of 12 months.