Why UK Residents with Properties in Italy and Spain need to pay attention
When Marco moved from Milan to London in 2018, he kept the family apartment overlooking Lake Garda.
At first, the property remained empty for much of the year. Then friends suggested listing it on Airbnb.
The bookings started arriving.
Soon, the apartment was generating a healthy stream of rental income from tourists visiting northern Italy.
Like many UK taxpayers with overseas holiday properties, Marco discovered that the UK’s Furnished Holiday Let (FHL) regime offered several valuable tax advantages. Mortgage interest relief was available, capital allowances could be claimed on qualifying assets, and the business enjoyed a more favourable tax treatment than a standard residential rental property.
Everything seemed straightforward.
Until now.
From 6 April 2025, the UK Government abolished the Furnished Holiday Letting regime.
For thousands of UK residents who own holiday homes in Italy, Spain, Portugal and other overseas locations, the consequences are only now becoming apparent as they prepare their 2025/26 tax returns.
The forgotten Group of Property Owners
Most commentary surrounding the abolition of the FHL regime has focused on cottages in Cornwall, holiday homes in Wales or short-term rentals in the Lake District.
However, many UK taxpayers have a very different profile.
At Vectigalis Tax, we frequently advise:
- Italian nationals who moved to the UK but retained family property in Italy.
- British expatriates who purchased retirement properties in Tuscany, Sicily or Puglia.
- Investors who own holiday apartments on the Costa del Sol, Costa Blanca or the Balearic Islands.
- Families with inherited properties generating seasonal rental income overseas.
Historically, many of these overseas properties qualified as EEA Furnished Holiday Lets.
As a result, they benefited from broadly the same UK tax treatment as equivalent UK holiday lets.
That treatment has now disappeared.
The first surprise: Higher Taxable Profits
Many owners assume that if the rental income has not changed, the tax position should remain broadly the same.
Unfortunately, that is often not the case.
Before the abolition, mortgage interest and financing costs relating to a qualifying furnished holiday let could generally be deducted when calculating taxable profits.
Now, former holiday lets are treated in the same way as ordinary residential rental properties.
For many higher-rate taxpayers, particularly those with mortgages secured on properties in Italy or Spain, the result may be a significantly higher UK tax liability.
The property generates the same income.
The tax bill increases.
The Double Tax dimension
For overseas properties, the analysis becomes even more complex.
Consider a UK resident who owns an apartment in Rome or Barcelona.
Rental income may already be subject to local taxation in Italy or Spain.
The UK generally provides relief for foreign taxes under the relevant double taxation treaty.
However, the abolition of the FHL regime changes how profits are calculated for UK purposes.
As a result, some taxpayers may discover that although foreign tax credits remain available, the underlying UK taxable profit has increased because finance costs are no longer treated as they were previously.
This can create unexpected cash-flow pressures and higher effective tax rates.
The Capital Allowance Issue nobody talks about
Many holiday property owners have invested heavily in their overseas properties.
New kitchens.
Air conditioning systems.
Furniture packages.
Appliances.
Security systems.
Under the previous FHL regime, capital allowances frequently played an important role in reducing taxable profits.
Following abolition, the position is far less generous.
Whilst transitional provisions may preserve certain historic claims, future expenditure will often receive a less favourable tax treatment.
Owners planning refurbishment projects in Italy or Spain should therefore review the tax implications before committing significant capital expenditure.
A Future Sale could be more expensive
Perhaps the biggest concern lies further ahead.
Many property owners are not planning to sell today.
They may sell in five years.
Ten years.
Perhaps when they retire.
Historically, qualifying furnished holiday lets benefited from access to certain capital gains tax reliefs more commonly associated with trading businesses.
The abolition of the regime means that future disposals may no longer qualify for those reliefs.
For a UK resident owning a villa in Tuscany or an apartment in Marbella that has substantially increased in value, this could translate into a significantly larger capital gains tax liability when the property is eventually sold.
A typical example
Consider a UK-resident taxpayer who owns a holiday property in Puglia generating £30,000 of annual rental income.
The property is financed through a mortgage costing £12,000 per year in interest.
Under the previous FHL rules, the interest expense would generally have reduced taxable profits directly.
Following abolition, the calculation is very different.
The economic profit remains unchanged.
The tax outcome does not.
For higher-rate taxpayers, the additional annual tax cost can be substantial.
Multiply that over several years and the cumulative impact becomes difficult to ignore.
Why International Property Owners need specialist advice
Many accountants correctly understand UK property taxation.
Many Italian and Spanish advisers correctly understand local tax rules.
What is often missing is an integrated analysis of both systems.
The interaction between:
- UK property income rules;
- foreign tax credits;
- double tax treaties;
- capital gains taxation;
- inheritance and succession planning;
- ownership structures; and
- future residency plans
requires a cross-border approach.
This is particularly important for UK residents with family connections in Italy or Spain, where future succession planning often becomes intertwined with property ownership.
How Vectigalis Tax can help
At Vectigalis Tax, we specialise in advising UK residents and internationally mobile families with assets across multiple jurisdictions.
Our clients frequently own:
- Holiday homes in Italy.
- Villas and apartments in Spain.
- Investment properties across Europe.
- Mixed UK and overseas property portfolios.
We can help you assess:
- The impact of the abolition of the Furnished Holiday Let regime.
- The interaction between UK and overseas tax rules.
- Capital gains tax exposure on future disposals.
- Property ownership structures.
- Inheritance and succession planning considerations.
- Opportunities to improve tax efficiency whilst remaining fully compliant with HMRC requirements.
If you own a holiday property in Italy, Spain or elsewhere overseas and are unsure how the new rules affect you, now is the ideal time to review your position before filing your next UK tax return.
For a confidential discussion, contact:
Angelo Chirulli FCA, ADIT, TEP
International Tax advisor
Cross-border property ownership creates opportunities—but also risks. The right advice today can prevent expensive surprises tomorrow.