The FTT case of Firth in relation to BPR for furnished holiday lets

After a steady stream of business property relief (BPR) cases in respect of furnished holiday lets (FHL) in recent years starting with Pawson in 2013 (CRC v Lockyer & Robertson (personal representatives of Pawson) [2013] UKUT 050 (TCC)) a claim in respect of an ‘aparthotel’ has been rejected by the First-tier Tribunal in the case of Firth (Mr Bruce Firth and Mrs Rita Firth as the trustees of The L Batley 1984 Settlement [2022] UKFTT 219 (TC)).

The run of BPR cases has mostly gone against the taxpayer with Graham (personal representatives of Grace Graham (deceased) [2018] UKFTT 0306 (TC)) being the only FHL case where the BPR claim was allowed – at least where the guests were humans. The taxpayer in CRC v Personal Representatives of the Estate of Maureen N Vigne (deceased) [2018] UKUT 0357 (TCC) who had equine guests at a livery was more successful....