Statutory 2026/27 Post-Abolition Transition Engine

FHL Tax Calculator UK (2026/27)

Calculate the direct tax impact of the abolition of the Furnished Holiday Lettings regime. Model Section 24 mortgage interest restrictions, the loss of 100% Capital Allowances, and the 3-year BADR cessation window under HMRC rules.

ITTOIA 2005 s.272ASection 24 Mortgage Restriction3-Year BADR Cessation Rule
Popular Holiday Let Scenarios

Holiday Let Income & Mortgage Costs

£48,000.00
£5,000£100,000£200,000
£14,000.00
£0£40,000£80,000
£16,000.00

Under the post-abolition rules, this interest cannot be deducted from profit. You only receive a 20% basic rate tax credit.

£5,000.00

100% Annual Investment Allowance (AIA) is lost. Standard residential lets can only claim Replacement of Domestic Items Relief (RDIR).

£65,000.00
£0 (Basic)£50,270 (Higher 40%)£125,140+ (45%)
Statutory Transition Impact

Annual Tax Liability Shift

+£5,200.00 / yrExtra Tax Burden
Old FHL Regime
£5,200.00
Take-home: £7,800.00Effective: 40.0% of profit
New 2026/27 Rules
£10,400.00
Take-home: £2,600.00Effective: 80.0% of profit
Child Benefit Clawback Triggered: Artificially inflated Adjusted Net Income (£99,000) enters the £60,000–£80,000 HICBC taper.
Taxable Rental Profit (HMRC Base):£13,000.00£34,000.00
Mortgage Interest Deduction:Disallowed (£0)
Section 24 Tax Credit (20%):-£3,200.00
AIA Furniture Write-off:£0 (Lost)
Pension Relevant UK Earnings:£0 (Passive)
Ltd Company Alternative£3,420.00 CT

In a limited company SPV, mortgage interest remains 100% deductible as a business expense against Corporation Tax (19%–25%).

Statutory Context & Legislation

The Abolition of the Furnished Holiday Lettings (FHL) Regime

For over four decades, furnished holiday lettings enjoyed privileged commercial tax treatment under Chapter 6 of Part 3 of the Income Tax (Trading and Other Income) Act 2005 (ITTOIA 2005) and Sections 241 to 241A of the Taxation of Chargeable Gains Act 1992 (TCGA 1992). These statutory provisions treated qualifying short-term holiday rentals as active commercial trades rather than passive property investment businesses.

Following legislative reform enacted under the Finance Act 2025, the separate FHL regime was abolished from 6 April 2025. In the 2026/27 tax year, all furnished holiday accommodation properties are fully integrated into standard UK residential property businesses. Holiday let operators face identical statutory rules to standard buy-to-let landlords, fundamentally altering net profitability, mortgage finance deductibility, and capital gains relief.

FHL Regime vs Standard Residential Property (2026/27)

Tax FeatureOld FHL Regime (Pre-April 2025)New 2026/27 Regime (Abolished)
Mortgage Finance Costs100% deductible as business expenseDisallowed; 20% basic rate tax credit only
Capital Allowances (Furniture/Fittings)Up to £1,000,000 Annual Investment Allowance (AIA)AIA banned; Replacement of Domestic Items (RDIR) only
Pension Relevant EarningsNet profits qualified as relevant UK earningsTreated as passive income; £0 pension capacity
Capital Gains Tax on SaleBADR eligible at 10% / 14% (Rollover / Gift Relief)Standard residential CGT (18%/24%) after transition
Profit Splitting Between SpousesFlexible profit allocation regardless of ownershipStrict 50/50 default split unless Form 17 valid

The Section 24 Mortgage Interest Trap Explained

The most acute financial shock of FHL abolition stems from Section 272A ITTOIA 2005, universally known as Section 24. Under Section 24, mortgage interest and other financing costs (such as arrangement fees and loan interest) cannot be deducted from gross rental turnover to arrive at net taxable profit.

Instead, landlords are taxed on their gross profit before finance costs, and are subsequently granted a tax reduction equal to 20% of the finance costs under Section 274A ITTOIA 2005. For higher rate (40%) and additional rate (45%) taxpayers, this creates an immediate structural tax increase:

  • Higher Rate (40%) Taxpayers: Lose 40% relief and receive only 20% back, suffering an effective 20% tax penalty on every pound of mortgage interest paid.
  • Artificial Income Inflation: Because mortgage interest is not deducted, your Adjusted Net Income (ANI) surges. An individual earning £45,000 from employment and £25,000 in gross holiday let profits (with £15,000 in mortgage interest) sees their ANI jump from £55,000 to £70,000.
  • High Income Child Benefit Charge (HICBC): Pushing ANI into the £60,000 to £80,000 band triggers clawback of Child Benefit under Section 681C ITEPA 2003.
  • The £100,000 Taper Trap: If ANI crosses £100,000, the landlord loses £1 of Personal Allowance for every £2 of income, creating a savage 60% marginal income tax rate.

The 3-Year BADR Cessation Window (TCGA 1992 s.169I)

Holiday let operators planning an exit should pay critical attention to the 3-year post-cessation rule under Section 169I(4) TCGA 1992. Under standard business asset rules:

If your holiday accommodation met the statutory FHL conditions (105 days let, 210 days available, commercial basis) for a continuous 2-year period up to 5 April 2025, and the commercial trading business ceased on that date, you have exactly 3 years from the date of cessation (until 5 April 2028) to sell the property and claim Business Asset Disposal Relief.

Key Financial Saving in 2026/27:

In 2026/27, the statutory BADR rate is 18%. Without BADR, disposals of UK residential property attract standard residential CGT rates of 24% for higher/additional rate taxpayers. On a £150,000 capital gain, claiming BADR saves £9,000 in net tax.

Frequently Asked Questions About FHL Abolition

Frequently Asked Questions

Clear answers based on official HMRC rules and statutory guidance.

The Furnished Holiday Lettings (FHL) tax regime was abolished with effect from 6 April 2025 for Income Tax and Capital Gains Tax purposes (and 1 April 2025 for Corporation Tax). For the 2026/27 tax year, all short-term holiday accommodation properties are treated identically to standard UK residential buy-to-let property businesses under Part 3 of the Income Tax (Trading and Other Income) Act 2005 (ITTOIA 2005).

Keep income, cash flow and tax separate

Rental receipts less the allowable expenses supported by the tool form the starting point. Mortgage capital repayments are not deductible rental expenses.

An individual residential landlord may receive a limited basic-rate finance-cost tax reduction rather than deducting interest from profit. Company ownership and furnished holiday letting transitional rules require their own treatment.

Check the rules for your circumstances

Official guidance supports the rules described here; it does not approve or certify this calculator. Confirm dates, eligibility and unsupported cases before making a financial decision.