Acorn Strategy Desk · Portfolio Incorporation & Refinance
Beat Section 24 tax restrictions. Learn how professional landlords structure property incorporation using Section 162 Relief, Schedule 15 SDLT strategies, and Director's Loan Accounts.
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The Strategy
Why professional landlords move portfolios out of personal names and into a UK limited company.
Know the Risks
Incorporation fails on tax qualification, refinance capacity, or anti-avoidance compliance. Here is how each is handled.
HMRC scrutinises whether your portfolio constitutes a genuine 'business' or a passive investment. Demonstrating active management, multiple properties, and formal bookkeeping is critical for S162 CGT deferral.
Mortgages cannot simply be transferred. Lenders must replace your personal mortgages with new SPV Buy-to-Let mortgages. Acorn packages your whole portfolio with specialist lenders who underwrite the transition simultaneously.
Forming a partnership solely to avoid SDLT triggers HMRC anti-avoidance rules (GAAR). The partnership must be a genuine, pre-existing commercial entity with commercial trading history.
The Process
Four coordinated stages, run alongside your tax specialist and conveyancer.
A chartered tax specialist confirms your Section 162 and SDLT eligibility before anything moves.
Establish the UK Ltd Company (SIC 68209) and obtain RICS valuations across the portfolio.
Acorn Finance secures SPV term sheets to refinance the existing personal debt in one coordinated package.
Conveyancers complete the asset transfers, personal mortgages are cleared, and net equity is credited to your Director's Loan Account.
Interactive Tool
Model the equity that lands on your Director's Loan Account and the annual Section 24 drag an SPV structure removes.
Personal Income Tax Rate
Illustration assumes an indicative 5.50% average mortgage interest cost, a 20% basic-rate interest credit under Section 24, and Corporation Tax at 25% on net company profit.
Personally you would pay roughly £35,900 a year at the higher rate (40%), versus about £14,875 of Corporation Tax inside the SPV — while £900,000 of equity sits on your DLA to draw back tax-free.
Request SPV Incorporation Refinance ReviewIndicative illustration only, ignoring CGT, SDLT, personal allowances and other income. Actual outcomes depend on your full tax position and must be confirmed by a qualified tax specialist.
Acorn Finance is a specialist credit broker authorised and regulated by the FCA (#660207), not a tax advisory firm, chartered accountant, or legal practice. Incorporating a property portfolio involves complex statutory provisions including Section 162 TCGA 1992 (Incorporation Relief), Schedule 15 FA 2003 (SDLT Partnership rules), and anti-avoidance legislation (GAAR).
We arrange the commercial and SPV mortgage refinancing required to execute the transaction. We do not provide legal or tax advice. You MUST consult a qualified tax specialist or chartered accountant specialising in property incorporation before making any decisions.
Knowledge & Next Steps
SIC 68209 structures, ICR benchmarks and SPV lender criteria.
Moving capital between your trading company and your PropCo.
PRA portfolio underwriting for landlords with 4+ mortgaged BTLs.
Plain-English definitions for ICR, DSCR, S162, DLA and more.
Frequently Asked Questions