Costa taxa

A client whose UK business interests are otherwise unrelated has acquired some premises in Spain which will be converted to form luxury holiday accommodation.

They consist of some rooms with central facilities (kitchen living rooms swimming pool) which could be let to a family or group or separately to unconnected individuals. It is intended that our client's customers will have a choice of either occupying the premises on a full self-catering basis or the client will arrange for a 'live-in help' who will undertake the preparation of meals cleaning and so on for which of course a higher charge would be made.

If the accommodation were a pure holiday let then this would clearly be taxable as income from property. But is the addition of services which customers may not take up enough to make it a trade? Any comments on the...