A trade comprising the provision of ‘hospitality at home’ at a villa in Tuscany was commercial, and ‘sideways’ loss relief against the appellant’s general income was therefore allowable.
Summary
A trade comprising the provision of ‘hospitality at home’ at a villa in Tuscany was commercial (within ITA 2007, s 66), and ‘sideways’ loss relief against the appellant’s general income (under ITA 2007, 64) was therefore allowable.
Background
In December 2003, the appellant purchased a villa in Tuscany, which was rundown and dilapidated. However, it was not until 2006 when the appellant acquired legal title to the property in accordance with Italian law that he was able to commence restoration work. In August 2010 (and although the restoration was not fully completed until 2012), the villa received its first
