Until now, section 23 type relief can be set against all rental income of that person. From 1 January 2011 the use of the relief will in all cases be restricted solely to rental income from the section 23 property itself. Currently, when a person sells a section 23 property within the ten year period, any relief already given to him or her is clawed back and given to the new owner, who only has to hold the property for the balance of the period. From 1 January 2011 the claw-back will continue to apply but the new owner will get none of the relief.

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