Income from furnished lettings is part of the taxpayer's rental
business. Generally the same rules apply as for other lettings.
But where a taxpayer lets a residential property furnished,
plant and machinery capital allowances can’t be claimed on
furniture, furnishings or fixtures within the property. Instead a
deduction can be claimed for either:
or
This is ESC/B47. More details about what this concession covers
and how it is operated are given below.
A taxpayer may let both furnished and unfurnished property.
If so, you must ensure that the 10% is calculated only on the net
rent from the furnished lettings.
If a landlord receives a premium for the grant of a lease of
furnished residential property then the chargeable amount of the
premium is included in the ‘net rent’ for the purposes
of computing the 10% wear and tear allowance for the relevant tax
year (see
PIM1200 onwards).
Before 1975-76, when the general 10% basis started, there
were several bases in common use. We will not disturb these so long
as the let properties to which they apply remain in the same
ownership and they continue to be used. But a taxpayer can change
to the 10% basis if they wish. Any new properties must use the 10%
basis.
Furnished holiday lettings are different because plant and machinery capital allowances may be claimed as if the activity were a trade. For these lettings a taxpayer can claim plant and machinery allowances on plant and machinery in the accommodation and the wear and tear allowance isn’t available - see PIM4100 onwards.
The 10% wear and tear allowance is only designed to provide a measure of relief for the depreciation of the plant and machinery within a residential property. It isn’t intended to cover:
The wear and tear allowance is calculated by taking 10% of the
net rent received for the furnished residential accommodation. To
find the ‘net rent’ you deduct charges and services
that would normally be borne by a tenant but are, in fact, borne by
the taxpayer (for example, council tax, water and sewerage rates
etc).
The 10% deduction is given to cover the sort of plant and
machinery assets that a tenant or owner-occupier would normally
provide in unfurnished accommodation. These are things like:
This list isn’t meant to be complete but gives an idea of
the assets the wear and tear allowances covers.
Title to the 10% deduction does not depend on the provision
of each and every item in the list. The relief is calculated simply
on the net rents and not on the cost of particular items. But the
deduction is only due if furnished accommodation is genuinely
provided. A furnished property is one that is capable of normal
occupation without the tenant having to provide their own beds,
chairs, tables, sofas and other furnishings, cooker etc. The
provision of nominal furnishings will not meet this requirement. If
the accommodation isn’t furnished, or only partly furnished,
the 10% wear and tear allowance isn’t due.
The possible advantages of the 10% wear and tear allowance over the alternative, (the renewals allowance) are that:
If a taxpayer chooses to take the 10% wear and tear allowance, they can’t later claim for the cost of replacing the assets (but they can claim the cost of repairing them). Nor can they deal with some assets on one basis and some the other. If they take the 10% wear and tear allowance that is the only relief they can have for the depreciation of plant and machinery (furniture, furnishings and fixtures etc) of a type that, in unfurnished accommodation, a tenant would normally provide for himself (see the list above).
However, in addition to the 10% allowance, a taxpayer can also
deduct the net cost of renewing or repairing fixtures that are an
integral part of the buildings. The net cost means the cost of the
replacement less any amount received for the old item. See below
for renewals of fixtures in unfurnished property.
Fixtures integral to the building are those that are not
normally removed by either tenant or owner if the property is
vacated or sold. For example, baths, washbasins, toilets, central
heating installations. Expenditure on renewing such items is
normally a revenue repair to the building. It is due even though
the 10% wear and tear allowance has been deducted.
But a taxpayer cannot deduct:
The original cost of installation means either:
For more about capital expenditure (not allowable) and repairs (allowable) see PIM2020.
The cost of replacing plant and machinery supplied with the property can be claimed as an expense where neither the 10% wear and tear allowance nor plant and machinery capital allowances are claimed. This is called the ‘renewals basis’. It is like the wear and tear allowance for furnished letting in that:
The renewals allowance is also available for unfurnished
property. Here we will mainly be concerned with fixtures. But the
taxpayer may also provide some plant and machinery assets to the
tenant (such as a heating boiler) although the let can’t be
regarded as ‘furnished’. The taxpayer can claim a
renewals deduction in the same way but they can’t claim the
10% wear and tear allowance because they don’t come within
the terms of ESC/B47 (see above).
Whatever basis is chosen must be followed consistently. It
isn’t possible to chop and change between the wear and tear
allowance and the renewals allowance from year to year.
Malcolm replaces a washing machine in a flat he lets. He sells
the old washing machine for £20 and buys a washer dryer
costing £559 to replace it. The cost of buying a new washing
machine like the old one would have been £399. Malcolm deducts
from the £559 both the £20 received for the old machine
and the £160 that represents the difference in cost between a
washing machine and a washer dryer. His renewals deduction is
therefore £379.
Sometimes it is impossible to find the current cost of
replacing an old asset with something identical. In the previous
example, the old washing machine may be of a kind which is no
longer made. Common sense has to be used to find the cost of a
reasonable equivalent modern replacement.
Further guidance on the renewals basis can be found at
BIM46935.
Where a taxpayer claims that the 10% allowance is inadequate, you should say that HMRC is only prepared to give this concession on its own terms. It is always open to the taxpayer at the outset to adopt the renewals basis instead. In other cases the 10% allowance may seem over-generous, but you should not seek to restrict the deduction for that reason.
