Revenue Precedents

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? 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. IT953544