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Posted Wed, 17 Jan 2024 21:07:59 GMT by
My reading of the advice in the manual, is that capital can be withdrawn from the value of a FHL in the form of a loan or mortgage, and that the interest thus incurred will become an allowable business expense. Apparently, there has been a change in attitude at HMRC that is not a reflection of a change in the guidance. It is now expected that if the interest is to be offset against tax liabilities, any capital realised in this way must solely be for use within the property business . Please can someone from HMRC clear up this point.
Posted Fri, 19 Jan 2024 12:20:28 GMT by HMRC Admin 21 Response
Hi parallelcottages,
Thank you for your question. We can only follow the guidance available to us and BIM45700 relates to the withdrawal of profits/capital in a business and substitute it for interest bearing loan which can qualify as an allowable deduction on the proviso that the loan is used as working capital in the self same business. You offered no details to your question and further it is not an approriate question for the income from property forum. I strongly recommend that you correspond with HMRC, outlining your observations with the case you refer to. 
Thank you.

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