FHL Abolition: What Changed from 6 April 2025
- Mortgage interest: full deduction gone — now Section 24 applies (20% tax credit only)
- Capital allowances on furnishings: no longer available — replacement of domestic items relief only
- CGT: BADR (10%) gone — now standard residential rates (18% basic / 24% higher)
- Pension contributions: FHL profits no longer count as relevant UK earnings
- Losses: FHL losses can no longer offset other income
FHL Abolition Impact Calculator
Enter your FHL figures to compare tax under the old FHL regime versus the new normal property income rules from April 2025.
Capital allowances benefit shown is first-year saving from 100% AIA on stated furnishings value. Section 24 modelled as: gross profit calculated on income minus other expenses (not mortgage interest), then 20% tax credit applied. Seek specialist advice for your exact position.
What Was the FHL Regime?
The Furnished Holiday Lettings (FHL) regime was a set of special tax rules that applied to short-term holiday lets in the UK and the European Economic Area that met certain qualifying conditions. To qualify, a property had to be available for letting for at least 210 days per year, actually let for at least 105 days, and not normally occupied for continuous periods exceeding 31 days (the long-term occupation condition).
Properties meeting these conditions were treated as trading income rather than investment income for most tax purposes. This gave FHL landlords access to reliefs normally reserved for trading businesses: full mortgage interest deductibility (not subject to Section 24), capital allowances on furnishings and equipment (including 100% Annual Investment Allowance), Business Asset Disposal Relief for CGT at the 10% rate, the ability to roll over gains, and treatment of profits as relevant UK earnings for pension contribution purposes.
The government announced the abolition of the FHL regime in Spring Budget 2024, to take effect from 6 April 2025, as enacted in Finance Act 2025.
Section 24 Mortgage Interest Restriction
The most financially significant change for many FHL landlords is the loss of full mortgage interest deductibility. Under the old FHL regime, mortgage interest was deductible from rental income in full, reducing taxable profits. Under the normal residential letting rules (Section 24, as applied from 2020/21 for standard buy-to-let landlords), mortgage interest is not deductible from rental profits. Instead, a 20% basic rate tax credit is available on the finance costs.
For basic rate taxpayers, the practical difference is modest because the 20% credit effectively mirrors a 20% deduction. But for higher rate (40%) and additional rate (45%) taxpayers, the change is significant. A higher rate taxpayer paying £8,000 per year in mortgage interest would previously save £3,200 in tax (40% of £8,000). Under Section 24, they only receive a £1,600 credit (20% of £8,000) — an annual extra tax cost of £1,600 from this element alone, even if the property profit is unchanged.
Critically, Section 24 can cause some landlords to appear to make a profit on paper (before the credit) even if their cash position is break-even or negative. This can affect other areas of their tax return, including child benefit clawback calculations and personal allowance tapering above £100,000.
Capital Allowances and Replacement of Domestic Items
Under the FHL regime, landlords could claim 100% Annual Investment Allowance (AIA) on furnishings, equipment, and fixtures such as beds, sofas, white goods, carpeting, and boilers. A newly furnished FHL property could generate a substantial first-year capital allowance claim, often fully covering the capital cost in year one.
From April 2025, FHL properties are treated like standard residential lets. Capital allowances on furnishings are not available for residential property. Instead, only replacement of domestic items relief applies — which covers the cost of replacing items like-for-like. Initial provision of items is not covered, and upgrades beyond like-for-like are only partially deductible.
For an FHL landlord with £15,000 of furnishings and equipment, the loss of AIA means roughly £6,000 of tax relief (at 40%) that would have been available in year one of the old regime is no longer claimable.
CGT: Business Asset Disposal Relief Gone
Under the FHL regime, gains on the disposal of FHL properties qualified for Business Asset Disposal Relief (previously Entrepreneurs' Relief), giving a CGT rate of just 10% on qualifying gains up to the lifetime limit of £1 million. This was a substantial advantage compared to the standard CGT rates on residential property.
From April 2025, former FHL properties are residential property for CGT purposes. Gains are taxed at 18% for basic rate taxpayers and 24% for higher and additional rate taxpayers. On a gain of £80,000, a higher rate taxpayer would previously have paid £8,000 in CGT (10% BADR rate); they now pay £19,200 (24%) — an increase of £11,200 on that sale alone.
Rollover relief and holdover relief for trading assets, which were available for FHL properties under the old regime, are also no longer available from April 2025.
Pension Contribution Impact
Under the FHL regime, FHL profits counted as relevant UK earnings for the purposes of calculating pension annual allowance contributions eligible for tax relief. This was particularly valuable for FHL landlords with limited other employment income — their FHL profits could support pension contributions and attract the associated tax relief.
From April 2025, FHL income is property income and does not count as relevant UK earnings. If FHL income was your primary source of relevant earnings, your ability to make pension contributions with full tax relief may be significantly reduced. For example, if your only relevant earnings were £30,000 from FHL, you could previously contribute up to £30,000 per year to a pension with tax relief. From April 2025, if you have no other relevant earnings, your pension contribution limit for tax relief purposes falls to the minimum £3,600 per year.
Frequently Asked Questions
When was the FHL tax regime abolished?
The Furnished Holiday Lettings (FHL) tax regime was abolished from 6 April 2025. From that date, FHL properties are taxed as normal UK property income rather than under the previous preferential FHL rules.
What tax benefits did FHL landlords lose from April 2025?
FHL landlords lost: full mortgage interest deductibility (now Section 24 applies), capital allowances on furnishings, Business Asset Disposal Relief at 10% CGT, ability to treat profits as relevant UK earnings for pension contributions, and ability to offset FHL losses against other income.
What is Section 24 and how does it affect former FHL landlords?
Section 24 restricts mortgage interest deductibility for residential landlords. Instead of deducting full interest against rental income, landlords receive only a 20% basic rate tax credit. Higher rate taxpayers are significantly impacted as they previously saved 40% on interest costs.
Can I still claim capital allowances on FHL properties after April 2025?
No. From April 2025, FHL properties follow normal residential letting rules. Capital allowances on furnishings are not available. Only replacement of domestic items relief applies for like-for-like replacements.
What CGT rate now applies when selling a former FHL property?
From April 2025, former FHL properties are taxed as residential property for CGT. The rate is 18% (basic rate) or 24% (higher/additional rate). Business Asset Disposal Relief giving the 10% rate is no longer available.
Does the FHL abolition affect pension contribution limits?
Yes. FHL profits no longer count as relevant UK earnings. The amount you can contribute to a pension with tax relief depends on your relevant earnings, so landlords who relied on FHL income for this purpose may face a reduced pension contribution allowance.
Can I use a limited company to mitigate the impact?
Some landlords are considering incorporation. However, this involves SDLT on transfer, mortgage complications, set-up costs, and ongoing accounting. Specialist advice is essential — there is no simple fix and incorporation is not right for every situation.
What is replacement of domestic items relief?
Replacement of domestic items relief allows deduction for the cost of replacing items like beds, sofas, white goods, and carpets on a like-for-like basis. It does not cover initial provision or upgrades beyond the equivalent replacement item.
How does the FHL abolition affect my Self Assessment return?
From 2025/26, report former FHL income in the UK property income section of Self Assessment (not the FHL section). Section 24 now applies and capital allowances on furnishings cannot be claimed.
Are there transitional rules for FHL properties after April 2025?
HMRC published transitional guidance. Capital allowance pools had specific treatment at the point of regime change. Check HMRC's guidance at gov.uk for your property's exact transitional position.
Can I still use accumulated FHL losses after April 2025?
Losses accumulated under the old FHL regime may have specific transitional treatment depending on when they arose. Specialist advice is needed for loss utilisation under the post-abolition rules.
Was the FHL abolition challenged legally?
Various property bodies lobbied against the change but the measure was enacted in Finance Act 2025 and took effect from 6 April 2025 as planned. No legal challenge reversed the abolition.