Comparing Investment Property Valuation under FRS 102 and FRS 105 Micro Entity Accounts

Investment property valuation is a critical aspect of financial reporting, influencing stakeholders’ perceptions and strategic decisions. In the UK, two primary financial reporting standardsโ€”FRS 102 and FRS 105โ€”offer differing approaches to investment property valuation. Understanding these differences is essential for entities to make informed choices aligning with their financial reporting objectives


FRS 102: Fair Value Measurement

FRS 102 mandates that investment properties be measured at fair value at each reporting date, with changes recognized in profit or loss. This approach reflects current market conditions, providing stakeholders with up-to-date information on the property’s value.โ€‹

Key Features:

  • Fair Value Requirement: Investment properties must be revalued to fair value annually.โ€‹
  • Profit or Loss Impact: Gains or losses from revaluation are recognized in the income statement.โ€‹
  • Deferred Tax Consideration: Revaluation gains may necessitate recognizing deferred tax liabilities.โ€‹Steve Collings

Implications:

  • Enhanced Transparency: Fair value accounting offers a realistic view of asset values, aiding stakeholders in decision-making.โ€‹
  • Volatility in Earnings: Fluctuations in market value can introduce volatility in reported profits.โ€‹
  • Credit Assessment: Up-to-date valuations can positively influence credit ratings by reflecting the current financial position.โ€‹

FRS 105: Historical Cost Measurement

FRS 105, applicable to micro-entities, requires investment properties to be measured at historical cost less accumulated depreciation and impairment. Revaluation to fair value is not permitted under this standard.โ€‹

Key Features:

  • Cost-Based Measurement: Assets are recorded at purchase price, adjusted for depreciation and impairment.โ€‹
  • No Revaluation: Fair value adjustments are not allowed, even if market values change significantly.โ€‹
  • Simplified Reporting: The standard aims to reduce the reporting burden for small entities.โ€‹

Implications:

  • Stability in Earnings: Absence of revaluation leads to more stable profit figures over time.โ€‹
  • Potential Understatement: Asset values may be understated compared to current market conditions, possibly affecting business valuation.โ€‹
  • Limited Insight for Stakeholders: Lack of fair value information may hinder stakeholders’ ability to assess the entity’s financial health accurately.โ€‹

Comparative Analysis: FRS 102 vs. FRS 105

AspectFRS 102FRS 105
Valuation BasisFair value with annual revaluationHistorical cost; no revaluation permitted
Impact on EarningsPotential volatility due to market fluctuationsStable earnings; no market-driven adjustments
Asset Valuation AccuracyReflects current market conditionsMay not represent true market value
Stakeholder InsightProvides transparent, up-to-date informationLimited visibility into asset appreciation
Credit Rating InfluencePositive, due to realistic asset valuationsNeutral or negative, due to outdated valuations
Business Valuation ImpactEnhanced, reflecting true asset worthPotentially diminished, due to conservative valuations

Strategic Considerations

Entities must weigh the benefits of transparency and accurate asset valuation against the simplicity and stability offered by each standard. FRS 102’s fair value approach may be advantageous for entities seeking to provide stakeholders with current financial information, potentially improving credit ratings and business valuations. Conversely, FRS 105’s cost-based approach simplifies reporting but may not capture the true economic value of investment properties.โ€‹IAS Plus

Recommendations:

  • Assess Entity Size and Complexity: Micro-entities may opt for FRS 105 for its simplicity, while larger entities might prefer FRS 102 for comprehensive reporting.โ€‹
  • Consider Stakeholder Needs: Entities aiming to attract investors or secure financing may benefit from the transparency of FRS 102.โ€‹
  • Evaluate Financial Strategy: Align the choice of standard with long-term financial goals and reporting objectives.โ€‹

Conclusion

The choice between FRS 102 and FRS 105 significantly impacts how investment properties are reported, influencing stakeholders’ perceptions and financial decision-making. Entities should carefully consider their specific circumstances, stakeholder requirements, and strategic objectives when selecting the appropriate financial reporting standard.โ€‹

Corporate Holiday Lets/Serviced Accommodation and the End of FHL Tax Benefits: Key Implications

In the Spring Budget 2024, the Chancellor announced a significant change that will directly impact companies owning furnished holiday lets/Serviced Accommodation (SA): the Furnished Holiday Lettings (FHL) tax regime will be abolished from April 2025.

This change marks the end of a beneficial tax regime that has been in place for decades, and it carries important implications for tax planning, particularly for companies that have structured their property investments to take advantage of FHL rules.

๐Ÿ“Œ What Is Changing?

From 6 April 2025, the FHL regime will no longer apply. This means:

  • No more capital allowances on items like furniture and fittings.
  • No Business Asset Disposal Relief (BADR) on the sale of FHL properties (previously allowing 10% CGT rate).
  • No rollover relief when reinvesting proceeds into other trading assets.
  • Section 24 applies to individuals and partnerships

๐Ÿ‘จโ€๐Ÿ’ผ Why Does It Matter for Companies?

While the FHL regime was originally designed with individuals in mind, many companies have also benefited from the enhanced deductions and CGT treatment. With its removal, companies will now be taxed in the same way as other property businesses.

This will particularly affect:

  • Profit extraction strategies โ€“ if profits reduce, dividends and director remuneration may need to be reassessed.
  • Incorporation plans โ€“ some landlords may reconsider moving personally owned FHLs into companies now that the tax advantages are disappearing.

๐Ÿ” What Should Companies Do Now?

  1. Review planned disposals: If youโ€™re an individual planning to sell a holiday let, the three-year rule allows disposals of holiday let properties up to April 2028 to qualify for BADR, provided the FHL business ceased before 6 April 2025, and all other conditions for BADR are satisfied. This includes ensuring that the disposal is made in good faith without a primary purpose of obtaining tax advantages. Clear evidence and statements may be required to support the claim for relief. BADR can apply to the sale of shares if the above conditions are satisfied. For example:
    • The individual must hold at leastย 5% of the sharesย in a trading company or group.
    • The shares must have been held for at leastย two years, and the individual must have been anย employee or officerย during this time.
    • The total gains eligible for BADR must not exceed theย lifetime limitย of ยฃ1 million for disposals made after 11 March 2020.
  2. Capital allowances: From 6 April 2025, existing capital allowances related to furnished holiday lettings can generally be carried forward under transitional rules. These allowances will be transferred to the appropriate pool for the corresponding property activity (UK or overseas property business). Elections and short-life asset treatments made before this date will remain valid, without a deemed disposal event as of 5 April 2025. However, capital allowances will not apply to new expenditure on former FHL properties after the regime’s abolition. Owners should carefully review their existing allowances and consider the transitional rules to maximise available relief.
  3. Profit forecasts: Update business plans and tax projections to reflect reduced tax efficiency from 2025.

๐Ÿ“ Final Thoughts

This change underscores the governmentโ€™s broader aim to simplify property tax treatment and reduce the favourable treatment of short-term letting. For corporate landlords operating holiday lets, this is a key moment to reassess tax strategy and ownership structure.

We are here to help, please book a meeting if you want to discuss the changes

Getting ready for MTD for Income Tax and Self Assessment

HM Revenue & Customsโ€™ (HMRC) Making Tax Digital initiative has been gradually evolving for several years now. But did you know that it will soon be mandatory for landlords and small businesses that pay tax through self-assessment to use HMRCโ€™s digital tax system.

Under MTD ITSA, taxpayers are required to submit five returns per tax year: four quarterly updates and a final declaration. The deadlines for the quarterly submissions are 5 August, 5 November, 5 February, and 5 May, with the final declaration due by 31 January following the tax year. While the final declaration effectively replaces the traditional Self Assessment return, taxpayers must still use it to report additional information and finalise their tax liability. Ensuring compliance with these obligations will require the use of compatible software and adherence to the prescribed deadlines.

Making Tax Digital for Income Tax & Self Assessment (or MTD for ITSA, as itโ€™s more commonly known) is likely to be a major change for some taxpayers.

So, are you ready for the upcoming MTD for ITSA rules?

What is MTD for ITSA?

Making Tax Digital (MTD) aims to bring tax into the digital age, moving from annual paper and online tax submissions to quarterly digital uploads of your tax information.

Having to keep detailed digital records sits at the heart of MTD. Taxpayers will need to record all incoming and outgoing transactions using compatible accounting software, and then share this information in an approved digital format with HMRC.

Who will be affected by the MTD for ITSA rules?

MTD for ITSA is already at the beta testing stage and some self-assessment taxpayers have opted in to the system already.

But if youโ€™re a landlord or sole trader who falls into the following categories, MTD for ITSA will soon become a mandatory requirement:

  • From April 2026, for those with qualifying income over ยฃ50,000
  • From April 2027, for those with qualifying income over ยฃ30,000

How do you get ready for MTD for ITSA?

If youโ€™re already using cloud accounting software to manage your finances, MTD for ITSA wonโ€™t be a major challenge. Youโ€™re already recording your numbers in a digital format and most of the popular accounting platforms will have MTD for ITSA templates you can fill out.But if youโ€™ve not embraced the latest in accounting tech, itโ€™s important to upgrade ASAP.

To stay compliant, youโ€™ll need to:

  • Keep your records in a digital format
  • Provide digital quarterly updates to HMRC
  • Be able to provide your ITSA return information to HMRC through MTD-compatible software.
  • Talk to us about preparing for MTD for ITSA

If youโ€™re concerned about how MTD for ITSA may affect your finances, come and talk to us

Weโ€™ll advise you on the best accounting software and give you guidance on upgrading and preparing your bookkeeping, accounting and tax procedures for MTD for ITSA.

steve@bicknells.net

Holiday Lets – Good news for Capital Allowances

At last, after a long wait since March 2024, we know what the legislation will be…….

Policy paper

Abolition of the furnished holiday lettings tax regime

Published 29 July 2024

https://www.gov.uk/government/publications/furnished-holiday-lettings-tax-regime-abolition/abolition-of-the-furnished-holiday-lettings-tax-regime

Operative date

The measure will have effect:

  • on or after 6 April 2025 for Income Tax and for Capital Gains Tax
  • from 1 April 2025 for Corporation Tax and for Corporation Tax on chargeable gains

Current law

The current law on the tax rules for furnished holiday lettings is contained in:

  • Part 3 of the Income Tax (Trading and Other Income) Act 2005
  • Part 4 of the Corporation Tax Act 2009
  • Part 7 (specifically sections 241 and 241A) of the Taxation of Capital Gains Act 1992
  • the Capital Allowances Act 2001

Proposed revisions 

This change will remove the tax advantages that current furnished holiday let landlords have received over other property businesses in 4 key areas by:

  • applying the finance cost restriction rules so that loan interest will be restricted to basic rate for Income Tax
  • removing capital allowances rules for new expenditure and allowing replacement of domestic items relief
  • withdrawing access to reliefs from taxes on chargeable gains for trading business assets
  • no longer including this income within relevant UK earnings when calculating maximum pension relief

After repeal, former furnished holiday let properties will form part of the personโ€™s UK or overseas property business and be subject to the same rules as non-furnished holiday let property businesses.

The following specific transitional rules will apply:

  • businesses withย FHLย properties will no longer be eligible for more beneficial capital allowances treatment but will instead be eligible for โ€˜replacement of domestic items reliefโ€™ in line with other property businesses โ€” where an existingย FHLย business has an ongoing capital allowances pool of expenditure, they can continue to claim writing-down allowances on that pool โ€” any new expenditure incurred on or after the operative date must be considered under the property business rules
  • under current rules a loss generated from aย FHLย property business can only be carried forward and utilised against future profits of that sameย FHLย business โ€” after the changes, formerย FHLย properties will be part of the personโ€™s UK or overseas property business as appropriate โ€” that property business will then include the amalgamated profits and losses of all the properties in that business
  • persons may have losses to carry forward from theirย FHLย business after repeal โ€” losses generated from thisย FHLย business will be permitted to be carried forward and be available for set off against future yearsโ€™ profits of either the UK or overseas property business as appropriate
  • under current rulesย FHLย properties are eligible for roll-over relief, business asset disposal relief, gift relief, relief for loans to traders, and exemptions for disposals by companies with substantial shareholdings โ€” after the changes eligibility for the reliefs will cease โ€” however, where criteria for relief includes conditions that apply in a future year these specific rules will not be disturbed where theย FHLย conditions are satisfied before repeal
  • in relation to business asset disposal relief, where theย FHLย conditions are satisfied in relation to a business that ceased prior to the commencement date, relief may continue to apply to a disposal that occurs within the normal 3-year period following cessation
  • there is also an anti-forestalling rule โ€” this will prevent the obtaining of a tax advantage through the use of unconditional contracts to obtain capital gains relief under the currentย FHLย rules โ€” this rule applies from 6 March 2024

Capital Allowances – Claim them now!

Now that we know you can continue to use the capital allowances pool after 5th April 2025 its worth claiming capital allowances now if you are eligible.

We had previously assumed there would a clawback on the 5th April 2025 by creating a balancing charge because the Holiday Let activity would cease, but now we know that won’t be the case, which is great news and a big relief for FHL owners.

Holiday Lets – Claim FHL CGT Reliefs now or lose them forever

It was announced in the March 2024 budget that the special treatment of Holiday Lets (FHL) would be abolished from the 6th April 2025. That’s in 10 months time!!

In 2017 there were around 8,000 FHLs by 2022 there were 111,000 in the UK, the growth has been incredible, which is why the Government have changed the rules to cash in and also to release properties for the long term let market.

Key Problems

Capital Allowances

One of the major benefits of holiday lets/serviced accommodation has been and is Capital Allowances. These have been claimed by both individuals and companies.

Many FHL owners have claimed between 20% and 40% of the property value saving considerable tax, its been the top advantage of holiday lets for most owners and its key reason behind personal ownership which allowed the profits offset by Capital Allowances to be extracted tax free.

Now the regime is ending (5th April 2025) the market value of the assets (Integral Features and Plant & Equipment) may need to be assessed and a balancing charge may be payable. This could effectively refund HMRC with the tax that had been reclaimed.

Interest Restriction

This won’t apply to companies.

Companies will have a clear tax advantage for FHL ownership in the future.

Individual FHL owners will be taxed in the same way as BTL owners, this means Interest will no longer be an allowable cost and instead they will get the finance allowance. This is fine if you are 20% tax payer but will mean additional tax for 40% tax payers.

Residential Letting – What is the Finance Cost Allowance and how are Unused Finance Costs used up? – Steve J Bicknell Tel 01202 025252

CGT Reliefs

If you sell or transfer your FHL now you can still benefit from generous Capital Gains Tax Allowances (SDLT LBTT LTT may be payable)

Business Asset Disposal Relief (BADR)

This was previously known as Entrepreneurs Relief, basically, subject to rules, if you dispose of your FHL business, the gain is taxed at 10%.

Its anticipated that the date of disposal will be critical. In other words, an individual who ceased their FHL business will only qualify for BADR if they dispose of their FHL by the earlier of three years from the date of cessation or 5th April 2025.

We donโ€™t expect the end of the regime on the 5th April 2025 to count as cessation for BADR, meaning you can then dispose of the property then claim BADR in the following three years.

So there is clear incentive to sell now before the change takes place.

HS275 Business Asset Disposal Relief (2024) – GOV.UK (www.gov.uk)

Rollover Relief

This allows the FHL owner to rollover over their gain into a new business property.

It is clear that this relief will not be available after 5th April 2025, however, if a sale took place before the deadline could the gain be rolled over into a new qualifying business property for example a shop?

Letโ€™s hope so, otherwise there will be no option but to pay the CGT rolled over.

HS290 Business Asset Roll-over Relief (2024) – GOV.UK (www.gov.uk)

Holdover Relief

Where the intention is to keep an FHL property within the family, there are a number of tax planning opportunities. FHL properties that meet the qualifying criteria are able to benefit from s. 165 business asset holdover relief, and they may also qualify for business property relief, so enabling a gift into trust without a lifetime inheritance tax charge. In the latter case, holdover relief under TCGA 1992, s. 260 would apply as it takes priority over s. 165.

Holdover relief for FHLโ€™s will end on 5th April 2025

Gift Hold-Over Relief – GOV.UK (www.gov.uk)

Incorporation Relief

Its likely that an FHL business will qualify for incorporation tax relief, this should continue after the 5th April 2025. The important factor is the level of activity as outlined in the Ramsey Case.

HS276 Incorporation Relief (2024) Roll-over relief on transfer of a business – GOV.UK (www.gov.uk)

Anti Forestalling

The Government announced at Spring Budget 2024 that the Furnished holiday lettings tax regime (FHL) will be abolished from April 2025. The Finance (No. 2) Bill 2024 will include an anti-forestalling rule to prevent access to capital gains tax reliefs through the use of unconditional contracts, to apply from 6 March 2024. This is yet to be enacted and may be subject to change.

The date of disposal is the date of an unconditional contract which in England and Wales is normally the date of exchange.

So CGT reliefs would be based on that date not the completion date.

What this means is that any contract has to complete by the 5th April 2025

The abolition of FHL Tax Breaks is supported by both Labour and Conservatives, in fact Labour wanted to make the change back in 2010, so its unlikely who ever wins the election will stop the changes taking place.

Contact Us

Now is time to consider your option, we can help, please get in touch, book a meeting or drop me an e mail steve@bicknells.net

What is a Non Dom?

city view at london

Non-Dom status is a term used to describe individuals who are not domiciled in the United Kingdom for tax purposes. This means that they are not considered to be permanent residents of the UK and are therefore not subject to UK tax on their foreign income and gains, unless they choose to be.

The UK residency status test is used to determine an individual’s residency status for tax purposes. The test takes into account a number of factors, including the number of days spent in the UK, the individual’s ties to the UK, and their intentions for the future. If an individual spends more than 183 days in the UK in a tax year, or has significant ties to the UK, they will be considered a UK resident for tax purposes.

You might find this blog helpful Where should you pay tax? (Statutory Residence Test) – Steve J Bicknell Tel 01202 025252

If an individual is a Non-Dom and chooses to be taxed on the remittance basis, they will only be taxed on their UK income and gains, as well as any foreign income and gains that they bring into the UK. This means that they can avoid paying tax on their foreign income and gains that are kept outside of the UK.

However, there is a 7-year charge for Non-Doms who have been resident in the UK for 7 out of the previous 9 tax years. This charge is designed to discourage individuals from using Non-Dom status as a way to avoid paying UK tax on their foreign income and gains. The charge is currently set at ยฃ30,000 per year, but may be higher for individuals who have been resident in the UK for longer periods of time.

In conclusion, Non-Dom status can be a useful tool for individuals who have significant foreign income and gains, but it is important to understand the UK residency status test and the potential tax implications of choosing to be taxed on the remittance basis. The 7-year charge for Non-Doms is also an important consideration for those who are considering using Non-Dom status as a way to avoid paying UK tax. It is always advisable to seek professional advice before making any decisions regarding tax planning.

steve@bicknells.net

Have you remortgaged? will that restrict the recovery of interest beyond the Section 24 rules?

Many Buy To Let properties were purchased in individual names, that was norm before, then from 2017/18 we saw the introduction of clause 24 (section 24).

Essentially Section 24 removes Interest from the property expenses and gives you tax relief (finance allowance) at 20% (basic rate). So Higher rate tax payers will pay more tax.

Historically, its been common for BTL owners to regularly remortgage and with draw capital, basically cashing in on house price rises.

But what many owners seem to have overlooked is that if the mortgage exceeds the original property value (including SDLT and related costs) plus any improvement costs, then the mortgage interest is further restricted.

Increasing a mortgage

If you increase your mortgage loan on your buy-to-let property you may be able to treat interest on the additional loan as a revenue expense, as long as the additional loan is wholly and exclusively for the purposes of the letting business.

Interest on any additional borrowing above the capital value of the property when it was brought into your letting business is not tax deductible.

If the mortgage is for a residential property then theย restrictions on interest from April 2017ย will apply.

Examples of how to work out Income Tax when you rent out a property – GOV.UK (www.gov.uk)

steve@bicknells.net

Commercial Property Capital Allowances Sideways Relief

IT rental business losses can be set against general income only to the extent that they are attributable to:

  • certain capital allowances,
  • certain agricultural expenses (see PIM4224).

Until the 2010-11 tax year, relief against general income could be claimed to the extent the loss was due to furnished holiday lettings. This is not available for tax years 2011-12 onwards, see PIM4130. Losses of a furnished holiday lettings business may now only be carried forward to use against future profits of that same furnished holiday lettings business.

Where a customer claims loss relief against general income, they must take the full amount of the loss available up to the amount of their general income. They canโ€™t opt to take a smaller amount, either they claim for the full loss or they claim for none (ITA07/S121).

PIM4220 – Property Income Manual – HMRC internal manual – GOV.UK (www.gov.uk)

The largest capital allowances are likely to be from Annual Investment Allowance claims.

Any taxpayer seeking to obtain in excess of ยฃ50,000 of otherwise unlimited income tax reliefs in any one year will find their deductions โ€˜cappedโ€™ (ITA 2007, s 24A). The โ€˜capโ€™ is the greater of:

  • 25% of their total income; or
  • ยฃ50,000.

steve@bicknells.net