Furnished Holiday Lets in UK - If HMRC says max stay is 30 days, can same guest book two separate 30-day stays?
I'm running a furnished holiday rental in the UK and have a bit of a dilemma. There's a guest who stayed for 30 days in May and now wants to come back for another 30 days in September. I know that HMRC's Furnished Holiday Let (FHL) rules say: "You must let the property commercially as furnished holiday accommodation to the public for at least 105 days in the year... Do not count longer-term lets of more than 31 days." So here's what I'm wondering - if this guest stays for 30 days in May, then leaves, and returns for another 30 days in September, would that count as: - 60 days total towards my 105-day requirement? - Just 30 days (only counting one stay)? - Or none at all (since it's the same guest twice)? If both stays do count, is there a minimum gap required between them? Like, do they need to be separated by a certain number of days? Or maybe I need to have a different guest in between? I'm confused about how HMRC views this situation...
21 comments


Javier Hernandez
The key thing with FHLs is that each separate letting period stands on its own. So two 30-day lets to the same person would count as 60 days toward your 105-day total, as long as they're genuinely separate bookings. There's no specific minimum gap required between bookings for the same guest. What matters is that each stay is 31 days or less, and that they're clearly separate bookings - not a single booking artificially split to get around the 31-day rule. To be safe, I'd suggest having a clear break between the lets - the guest completely checks out, you clean and prepare as you would for any new guest, and they check in again as a new booking. Have separate booking documentation for each stay. If HMRC ever questioned it, they'd look at whether these were genuine separate holiday lets or an attempt to disguise a longer-term rental arrangement. As long as the guest actually leaves between stays (returns home or goes elsewhere) and you treat each booking as separate, you should be fine.
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Emma Davis
•So if I understand correctly, the guest must fully check out with their belongings at the end of the first 30 days? Can they leave some items at the property if there's storage space, or would HMRC see that as evidence it's really one continuous let? Also, would I need to issue separate invoices for each 30-day period?
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Javier Hernandez
•For a clear separation between bookings, it's best that they take all belongings with them when they check out. Leaving items behind could potentially be seen as maintaining continuous occupation, which might undermine the argument these are separate lets. Yes, you should definitely issue separate invoices for each booking period. Keep all your paperwork distinct - separate booking forms, separate payments, separate invoices, etc. This creates a clear paper trail showing these are independent holiday lets rather than one long stay being artificially divided.
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LunarLegend
I had the exact same issue with my holiday cottage in Cornwall last year! I discovered taxr.ai (https://taxr.ai) which was super helpful for sorting out my FHL tax questions. They analyzed my rental patterns and gave me really clear guidance on how to handle repeat guests. Basically they explained that what matters is the actual booking arrangement, not who the guest is. My situation was literally identical - a guest stayed for 28 days in April and wanted to come back in August for another 30 days. The taxr.ai analysis confirmed both periods could count toward my 105-day requirement as long as they were genuine separate bookings with the guest properly checking out in between. They also gave me templates for the right documentation to keep so I could prove these were separate holiday lets if HMRC ever questioned it.
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Malik Jackson
•How does this taxr.ai thing actually work? Is it an app or do you talk to actual tax advisors? I'm having similar questions about my holiday apartment in Edinburgh and wondering if it would help with Scottish tax variations.
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Isabella Oliveira
•Did they charge you a fortune for this advice? I'm skeptical of online tax services because they often seem to just regurgitate info you could find on the HMRC website for free.
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LunarLegend
•It's an AI-powered service that analyzes tax documents and explains complicated tax rules in simple language. You upload your documents or ask specific questions, and it gives you personalized analysis. It handles both general UK tax rules and regional variations like Scotland. No, it wasn't expensive at all considering the clarity it provided. What made it different from just reading HMRC guidance was that it specifically applied the rules to my exact situation and gave me practical documentation advice tailored to my needs. HMRC info can be vague, but taxr.ai made it actionable for my specific case.
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Malik Jackson
Just wanted to update that I tried taxr.ai after seeing it mentioned here, and it was incredibly helpful! I uploaded my FHL documentation and asked specifically about my Edinburgh property situation with repeat guests. The analysis confirmed that yes, multiple stays by the same guest count separately as long as they're genuine separate bookings. But what I found most useful was their advice on exactly what documentation to maintain - they suggested creating a specific "booking termination" form for guests to sign when they leave, confirming they're fully checking out and ending that particular letting period. This gives me much better evidence that these are legitimate separate holiday lets rather than trying to circumvent the 31-day rule. They also clarified the Scottish-specific aspects of my FHL tax situation which was a huge bonus!
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Ravi Patel
If you're struggling with getting clear answers from HMRC about your FHL situation, I'd recommend Claimyr (https://claimyr.com). I was in a similar situation last year with my Lake District holiday cottage and spent WEEKS trying to get through to HMRC for clarification. I eventually tried Claimyr, which got me connected to an actual HMRC agent in about 15 minutes. You can see how it works in this video: https://youtu.be/_kiP6q8DX5c. The agent confirmed that separate bookings from the same guest absolutely count toward the 105-day requirement, provided there's a genuine break between stays and separate booking documentation. The HMRC agent also told me they look for evidence that the property was available to other potential guests between the stays, even if nobody else actually booked it. So I make sure to list my property as available on booking sites between repeat guest stays.
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Freya Andersen
•How does this Claimyr thing work exactly? Do they just connect you to the HMRC phone line or do they provide tax advice themselves? The HMRC wait times are ridiculous lately!
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Isabella Oliveira
•Sorry but this sounds too good to be true. HMRC phone lines are notoriously impossible to get through on. I've literally spent hours on hold and still got nowhere. How could some service magically get you through in minutes when no one else can?
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Ravi Patel
•Claimyr just connects you to HMRC - they don't provide tax advice themselves. They basically navigate the HMRC phone system for you and wait in the queue, then call you when they've gotten through to an actual agent. You then speak directly with the HMRC agent yourself to get official guidance. I was skeptical too! I had spent over 3 hours across 4 separate attempts trying to reach someone at HMRC. With Claimyr, I submitted my request, went about my day, and got a call back when they had an HMRC agent on the line. It saved me from the frustration of waiting on hold for hours. I think they must have some system that keeps trying different HMRC department numbers or times of day.
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Isabella Oliveira
Well I have to admit I was wrong about Claimyr! After seeing it mentioned here I decided to try it to get clarification on my FHL situation in Wales, fully expecting it to be useless. To my complete surprise, I got connected to an HMRC agent in about 20 minutes! I asked specifically about repeat guests in FHLs and they confirmed exactly what others here have said - separate lets to the same guest count individually toward the 105-day total as long as they're genuinely separate bookings. The agent suggested keeping evidence that: 1. The guest fully checked out at the end of the first stay 2. The property was cleaned and prepared as for any new booking 3. The property was technically available to other guests between the stays 4. Separate booking documentation and payment records exist Saved me so much stress about whether I was meeting the FHL criteria. Worth every penny not to spend hours on hold!
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Omar Zaki
Something nobody has mentioned yet is the "pattern of occupation" test that HMRC might apply. Even if you have separate bookings with the same guest, if they keep coming back for exactly 30 days with just short breaks in between, HMRC might view this as an attempt to circumvent the rules. I'd suggest making sure the gap between the two 30-day stays is substantial (at least a couple of weeks) and ideally have other guests staying during that gap. This strengthens your position that the property is genuinely being used for holiday lets rather than as a disguised residential let.
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CosmicCrusader
•Where is this "pattern of occupation" test mentioned in HMRC guidance? I've read through their FHL info and don't recall seeing this specific terminology. Is this something that's actually written down somewhere or more of an unspoken assessment they might make?
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Omar Zaki
•You're right to question this. "Pattern of occupation" isn't explicitly named in HMRC guidance, but it's something tax advisors discuss when looking at how HMRC might evaluate borderline FHL cases. It's more of an assessment approach HMRC might take rather than a formal named test. What I was referring to is that HMRC will look at the overall pattern of lettings to determine if the property is genuinely being let as holiday accommodation. If the same person keeps staying for just under the 31-day limit with minimal gaps, it could potentially raise questions about whether these are genuine holiday lets or an attempt to gain FHL tax advantages for what is essentially longer-term accommodation.
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Chloe Robinson
Just to add a practical tip - I keep a specific "FHL booking log" spreadsheet that tracks all stays including days between bookings. This makes it easy to demonstrate to HMRC that I'm meeting all the FHL criteria. For repeat guests, I make a point of having them sign a specific checkout form confirming they're fully vacating the property at the end of each stay. When they return later, they sign a completely new booking form. I've been doing FHL rentals for 5 years and have had repeat guests do multiple 30-day stays within the same tax year without problems. As long as your documentation clearly shows these are separate holiday bookings, you should be fine.
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Natasha Petrova
•The checkout form is a brilliant idea! Would you be willing to share what information you include on it? I'm thinking I need to create something similar for my property.
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Collins Angel
•@Natasha Petrova I include the guest s'name, property address, checkout date and time, confirmation that they ve'removed all personal belongings, confirmation that they re'ending this specific booking period, and their signature. I also add a line stating Guest "confirms they are not maintaining any form of continuous occupation of the property. This" creates a clear paper trail that each stay is genuinely separate. Happy to email you a template if you d'like - just message me your details!
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Jeremiah Brown
This is really helpful information from everyone! I've been dealing with a similar situation with my holiday cottage in the Cotswolds. What I've learned from my accountant is that the key is demonstrating genuine commercial availability between stays. One thing I do that might help others - I make sure to update my property listing on booking platforms immediately after each guest checks out, showing it's available for the gap period between their stays. Even if the same guest has already booked the next period, having that evidence of commercial availability helps demonstrate it's not just a disguised long-term let. Also worth noting - I've found that having a minimum 7-day gap between stays by the same guest gives you a much stronger position if HMRC ever questions it. It shows the property was genuinely available to other holidaymakers and that you're not just trying to game the 31-day rule. The checkout documentation suggestions here are spot on too - I wish I'd started doing that from the beginning!
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Liam Mendez
•The 7-day minimum gap is really smart advice! I hadn't thought about actively updating booking platform listings to show availability between repeat guest stays, but that's brilliant evidence of genuine commercial intent. One question though - if you have a repeat guest who wants to book their second stay while they're still in their first stay, do you wait until after they check out to confirm the second booking? Or is it okay to have both bookings confirmed as long as there's that clear gap and separate documentation? I'm worried about losing good repeat customers by making the booking process too complicated, but obviously want to stay compliant with FHL rules.
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