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Acorn Specialist Desk · Corporate BTL & SPV Structures

Limited Company Buy-to-Let Mortgages & Section 24 Tax Mitigation

Maximize rental yields using SPVs, Trading Company group structures, and 125% ICR stress testing. Whole-of-market access to 400+ corporate BTL lenders.

The 4 corporate BTL pathways

Choose the company structure that matches your tax and lending strategy

From clean SPVs to trading company groups and family investment companies, each route needs different lender evidence and solicitor packaging.

🛡️ SIC 68209 / 68100

Special Purpose Vehicle (SPV) BTL

Newly formed or existing property holding companies.

  • 125% ICR stress testing
  • 85% Max LTV
  • Automated 24-hr lender approvals
  • Intercompany loan deposits accepted
💼 NON-SPV TRADING CO

Trading Company BTLs (OpCo Mortgages)

Buying BTLs directly inside an active trading business such as IT, retail or manufacturing.

  • Specialist lenders who look past trading volatility
  • Solutions for existing properties tied to trading balance sheets
⚡ ZERO DIVIDEND TAX

Group Subsidiary SPVs (OpCo to PropCo Loan)

Moving trading profits into property without personal dividend tax exposure.

  • OpCo lends deposit to 100% owned PropCo subsidiary
  • Clean lender underwriting
  • Preserves trading cashflow
🏛️ ESTATE & IHT PLANNING

Family Investment Companies (FICs)

Passing rental wealth to the next generation tax-efficiently.

  • Alphabet share structures
  • Gifting growth shares
  • Sheltering rental portfolios from 40% Inheritance Tax

Section 24 ownership comparison

Personal name vs. limited company SPV

How interest relief, tax base and lender stress testing shift when rental property moves into a corporate structure.

FeaturePersonal Name OwnershipLimited Company SPV
Mortgage Interest ReliefRestricted to 20% basic rate credit100% Fully Deductible Expense
Tax BaseTaxed on GROSS Rental IncomeTaxed on NET Profit
Tax RateUp to 40% / 45% Personal Income Tax19% – 25% Corporation Tax
Lender ICR Stress Test145% @ 5.5%–6.5% (Borrow Less)125% @ 5.5% (Borrow Up to 20% More)
Intergenerational GiftingTriggers SDLT & CGTGift Shares without Land Conveyancing

Special feature

How to Use Trading Company Profits for BTL Deposits Without a Dividend Tax Bill

The Problem

Drawing profits from your trading company to buy a BTL personally triggers up to 39.35% Dividend Tax.

The Solution

Incorporate a 100% owned Subsidiary SPV (SIC 68209). Transfer trading cash as an Intercompany Loan.

The Result

Zero personal dividend tax triggered, full Corporation Tax deduction on mortgage interest, and clean 125% ICR lender approval.

Director security

Understanding Director Personal Guarantees (PGs) & Insurance

Lenders require Director PGs for SPV loans. Protect your personal family home against property market downturns using Personal Guarantee Insurance (PGI), which covers up to 80% of any lender shortfall.

Interactive Section 24 calculator

Estimate annual tax saved with an SPV

Compare personal-name Section 24 mortgage interest restriction against limited company corporation tax on net rental profit.

Annual gross rental income£60,000
Annual mortgage interest£30,000
Personal income bracket

Live tax comparison

Section 24 vs. SPV

Personal name tax bill
£18,000
Limited company tax bill (19%)
£5,700
Annual tax saved with SPV
£12,300

Modelled on £30,000 net rental profit after mortgage interest. Personal ownership applies Section 24 relief as a 20% credit on mortgage interest.

Indicative planning tool only. Tax depends on your full income, expenses, ownership, transfer costs, corporation tax bands and professional advice.

Child guides & planning tools

Go deeper on company BTL strategy

Use these knowledge desks to model tax, lender security and long-term ownership planning.

Corporate BTL FAQs

Answers for SPV landlords

Get Instant SPV Term Sheet

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