In a nutshell we are trying to establish is a property in France is an FHL or not.
At first glance it meets all of the FHL criteria but it is actually a French Leaseback property.
Under the rules of the lease the property is leased to the same entity for circa 40 weeks of the year. That entity then places holiday makers in it and fully manages it. I presume this means it is not an FHL?!
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Doesn't sound like an FHL to me
On the surface, it might look like one, but from the facts you give it sounds like the owner has granted a 40 week lease to another entity. That entity then uses the property in its FHL business. That entity could possibly (depending on whether it's resident in the UK etc) have an FHL business, but the owner doesn't. If the entity arranged the lets on behalf of the owner, it might be a different story.