Resort Areas - double rent allowance
06/06/1996
Query
Where a partnership takes a lease of a scheme of registered holiday cottages and lets them to tourists will the partnership be entitled to a double deduction for the rent which it pays under the lease?
Decision
If the partnership is occupying qualifying premises for the purposes of a trade and there is no connection between the lessor and the lessee it will be entitled to the double deduction. However it will be a question of fact whether the income arising from the cottages is chargeable Case I or Case V and whether the cottages will be occupied by the partnership. Prima facie, property which is let would appear not to be occupied by the lessor.
Income Tax
Section 354, Taxes Consolidation Act, 1997
Origin: RLS Division
File ref:IT953544