Can existing FHL Losses be split between co-owners when moving to new regime?

My husband and I jointly own a property in France which we have let out for the past 7 years when we haven’t been using it personally. As my husband works full time, I have managed the rentals myself, and so declared the income on a French tax return in my name only, and also on my UK SA return. In the UK I have losses b/f which I can use to reduce UK tax payable, together with the offset of the French tax paid. After the abolishment of FHL, I understand that the income will have to be split 50/50. Will my husband have access to the existing UK losses or will they be in my name only? And / or can we split the French property rental tax paid between us for UK offset purposes? I don’t want to have to change the way this is taxed in France to joint names as this is a headache I could do without, but it would seem very unfair if my husband can’t use either existing UK losses or future French tax paid to reduce his taxable income. Alternatively can we do a declaration of trust and fill in a form 17? We own the property in France under a tontine clause, which does not specify the relative percentage ownership for each party. Thank you.

Hi,
We would advise that as the years the losses arose were declared by yourself and should have been declared within 4 years of the losses arising, your husband would not be entitled to the benefit of earlier years losses, so would only be carried forwards by yourself against UK and overseas property business as appropriate.
You may wish to amend any years within the allowable 4 year window, however, this may affect your own tax liabilities.
Any losses arising from 5th April onwards would then be split between yourself and your husband under the new process.
PIM4210 
Thank you.