Existing portfolio structure
Owners, property values, acquisition costs and mortgages are mapped before alternatives are modelled.
Moving an existing rental portfolio into a limited company is a taxable transaction, not an administrative change. Capital Gains Tax, Stamp Duty Land Tax, refinancing, company tax and future profit extraction can all affect whether incorporation produces a sensible long-term result.
Our starting question is not whether companies are “better”. We compare the existing position with the proposed structure, quantify the immediate transaction costs and then model how the company is expected to be used.
Approximate figures are sufficient for the initial enquiry.
Prefer to call? 0800 135 7323
Before property is transferred, refinancing is committed or a company structure is implemented. Once the transaction occurs, many of the choices have already disappeared.
The transfer can create upfront tax and finance costs. Those need to be compared with the expected company tax position, reinvestment strategy and eventual extraction or disposal.
A meaningful review compares the whole transaction rather than focusing on one potential relief.
Owners, property values, acquisition costs and mortgages are mapped before alternatives are modelled.
The level and nature of the letting activity are reviewed where section 162 relief is being considered.
Property-level gains are calculated before the potential impact of incorporation relief.
SDLT is analysed independently; CGT incorporation relief does not itself determine the SDLT outcome.
The proposed company structure has to be capable of working with the actual lenders and debt.
Reinvestment, dividends, future disposals and succession are considered over the intended holding period.
Advice is useful only when the assumptions and transaction costs are visible.
Ownership, values, costs, debt and rental activity are established property by property.
Potential CGT, SDLT and relief positions are calculated from the proposed transaction.
Personal ownership and company ownership are compared over a sensible holding period.
The options, assumptions and areas requiring legal or lending implementation are set out clearly.
For relevant business transfers taking place on or after 6 April 2026, section 162 relief requires a claim. That makes it even more important to establish the business, asset-transfer and share-consideration conditions rather than assuming relief applies automatically.
A section 162 claim addresses Capital Gains Tax. It does not automatically solve the SDLT, mortgage, legal-title or commercial implementation issues arising from the same portfolio transfer.
HMRC's Capital Gains Manual covers the statutory requirements for section 162 relief.
Technical guidance ↗Current HMRC guidance sets out the claim requirement and timing for post-5 April 2026 transfers.
Claim guidance ↗It depends on the upfront tax and finance costs, future rental profits, reinvestment plans, intended extraction of company funds and likely exit.
No. The statutory conditions must be satisfied and for transfers from 6 April 2026 a claim is required.
There is no simple statutory property-count test. Whether the activity amounts to a business depends on the actual facts.
No. CGT incorporation relief and SDLT are separate regimes and need separate calculations.
Potentially, but that can affect the relief analysis and the commercial structure. The exact proposal needs reviewing before implementation.
Preferably. The tax analysis should inform the intended transaction before the legal and finance arrangements become fixed.