Clear, practical writing on the tax questions that matter to property developers and investors in the North West. No jargon for its own sake. Just the things worth knowing before they cost you.
Property tax is not one discipline. It is developer VAT, Stamp Duty Land Tax planning, capital gains, income tax structuring, company and SPV structures, and the rules around the Construction Industry Scheme. We write about the parts of it our clients in Liverpool, Manchester, Cheshire and across the wider North West actually have to make decisions on — and we try to do it without the jargon that usually surrounds the topic.
Most posts are written by Kieran Holsgrove, Director & Co-Founder, drawing on real client situations. We will not tell you what to do with your specific circumstances in an article — for that, you want a conversation — but you will come away understanding the moving parts and the right questions to ask.
Section 75A lets HMRC tax a series of property transactions as one notional deal at the highest value reached — with no need to show any tax avoidance motive. Why development structures built from options and sub-sales can walk into it.
Read the article →A gain on selling an investment property or a property company can be deferred, not eliminated, by reinvesting in an unrelated EIS-qualifying trade within three years — even though property development itself can never be the EIS target.
Read the article →A compulsory purchase order still creates a chargeable gain like any other land disposal. How TCGA 1992 sections 247 and 248 let a landowner roll that gain into replacement land bought within three years — and where the relief stops reaching.
Read the article →Business Investment Relief lets a non-dom fund a UK development company tax-free. The remittance basis it depends on was abolished from April 2025 — but transitional rules keep it alive for pre-2025 funds until 5 April 2028.
Read the article →Biodiversity net gain has been mandatory for most developments since February 2024. How the cost is taxed for a developer, why HMRC treats the sale of biodiversity units as standard-rated for VAT, and how a habitat bank operator's income is taxed on the other side.
Read the article →The basic tax point for construction services is the date the work is done, but the 14-day rule, an early payment and a separate rule for retention money can all move it. Why the wrong tax point puts VAT in the wrong return — and how retentions are treated differently.
Read the article →Sell or gift property into a company you control and SDLT is charged on market value, not the price paid — even at £0 consideration. Why CGT incorporation relief does nothing to stop it, and where the real reliefs sit.
Read the article →Since 6 April 2020, a non-UK resident company with UK rental income pays Corporation Tax, not the 20% income tax under the old NRLS rules. Why the change moves the rate, the loan interest rules and the filing obligations all at once.
Read the article →SDLT relief, a 100% first-year capital allowance, a 10% Structures and Buildings Allowance and a business rates holiday — what building inside a Freeport or Investment Zone tax site is actually worth, and where the North West's designated sites are.
Read the article →The Warm Homes Plan sets a single EPC C deadline of October 2030 for every privately rented home, with a £10,000 cost cap. Whether that spend is deductible now or added to base cost later depends on an old distinction landlords are about to meet at scale.
Read the article →An overseas investor who flies in regularly to check on a development can, without meaning to, tip themselves into UK tax residence. How the automatic overseas and UK tests work, and the sufficient ties day-count bands that decide everyone left in between.
Read the article →Pay an operating JV partner a flat monthly draw, give them little capital and no real say over decisions, and the salaried member rules can tax them as an employee. How Conditions A, B and C catch property development LLPs, and how to structure around them.
Read the article →Multiple dwellings relief ended on 1 June 2024, taking the standard SDLT planning route away from Build to Rent investors. Why the old six-or-more dwellings rule now carries the whole SDLT case for BTR forward funding deals, and the single-transaction test that decides whether it applies.
Read the article →Building an annexe or granny flat can be zero-rated for VAT, but only if it can be used and sold entirely separately from the main house. Why a planning condition tying the annexe to the main dwelling turns a zero-rated job into a 20% VAT cost.
Read the article →Selling a commercial building and leasing it straight back releases capital without giving up occupation, but the leaseback is a new lease in its own right for SDLT, and the sale only escapes VAT if it qualifies as a transfer of a going concern.
Read the article →SBA gives 3% a year straight-line relief on the cost of constructing or renovating a commercial building — but only if an allowance statement exists, and only for the shell, not the fixtures. Why developers routinely under-claim it.
Read the article →Solar panels, heat pumps and battery storage installed in residential accommodation qualify for VAT zero-rating, while the same equipment on commercial buildings sits in the capital allowances special rate pool. Why the dwelling-house rule blocks most landlords from allowances, and where developers can still claim.
Read the article →An overseas entity can't sell, lease over seven years or charge UK land without an Overseas Entity ID and a verified beneficial ownership statement. Who counts as a registrable beneficial owner, the annual update deadline, and what Land Registry does to the title when a structure falls out of compliance.
Read the article →Since 2024/25, cash basis is the default way individual landlords work out their property profit, not accruals — and most never actively chose it. The loan interest rule that quietly favours it, and when electing back into accruals still makes sense.
Read the article →A company buying a single dwelling worth more than £500,000 can face a flat 15% SDLT charge, whatever the mortgage. Genuine rental and development businesses can usually claim relief — but it comes with a 3-year clawback if a director moves in.
Read the article →Cross £90,000 of taxable turnover and VAT registration becomes compulsory — but for most developers, waiting that long means losing input VAT on land, professional fees and build costs along the way. Voluntary registration, pre-registration reclaims, and the deregistration trap on unsold stock.
Read the article →A SIPP or SSAS can buy commercial property outright, buy your trading premises back from your company, and lend money back to that company — tax-free within the pension. Why residential property is a trap, and the loanback conditions that catch people out.
Read the article →Sell the family home to downsize, move into care, or gift it before death, and the residence nil rate band it carried doesn't have to disappear with it. How the downsizing addition under IHTA 1984 sections 8FA-8FE claws it back, and where property clients trip on it.
Read the article →Grant a lease of 50 years or less for a lump sum premium and part of it is taxed as property income the year you receive it — not spread out, not deferred. The formula, the section 278 trap, and what a paying tenant can claim back.
Read the article →Property development, dealing in land and pure rental letting are excluded activities for EIS and SEIS relief — and the 2018 risk-to-capital condition closed the asset-backed workarounds that used to get around it. What happens if relief is later withdrawn.
Read the article →A jointly owned home or buy-to-let is usually exempt from the Trust Registration Service — until one owner dies and the survivor holds legal title partly on trust for someone who isn't on the deeds. What changed from 30 June 2026, and the penalties for missing the deadline.
Read the article →Buy a second-hand commercial building without fixing the fixtures' value by a joint section 198 election within two years, and the capital allowances on those fixtures can be lost for good — to you and to every future owner.
Read the article →Gifting the family home to children while continuing to live in it rent-free doesn't start the seven-year clock — the reservation of benefit rule keeps the house in your estate. What actually fixes it, and when the pre-owned assets tax applies instead.
Read the article →Employee Ownership Trusts let an owner exit without a buyer, but the Autumn Budget 2025 halved the CGT relief to 50%, and most buy-to-let holding companies never qualified as trading companies in the first place.
Read the article →A gift of property to a connected person is taxed as if it sold at full market value, and gift hold-over relief rarely helps an ordinary rental property. When section 260 relief and the SDLT rules on a mortgaged gift come into play.
Read the article →Moving a lettings portfolio into an LLP with a corporate member and skewing the profit share promises to sidestep Section 24's mortgage interest restriction, but HMRC's Spotlight 63 and its 2026 follow-up, Spotlight 63a, say the mixed membership partnership rules unwind it anyway.
Read the article →A deed of variation executed within two years of death can redirect an inherited property as if the deceased had left it that way from the start, but the deadline is a hard cut-off and the CGT base cost never resets.
Read the article →Winding up a finished development SPV can turn retained profit into a capital gain taxed at Business Asset Disposal Relief rates instead of dividend income, but a targeted anti-avoidance rule reclassifies the distribution as income if the shareholder carries on a similar trade within two years.
Read the article →Assigning a purchase contract to another buyer before completion normally keeps SDLT to a single charge, but taking early possession or starting site works first can turn that one charge into two.
Read the article →Holding UK residential property through an offshore company once kept it outside the Inheritance Tax net for non-doms. Schedule A1 closed that in 2017, and April 2025's move from domicile to residence has closed most of what was left.
Read the article →VAT grouping several development SPVs removes VAT from intra-group recharges and cuts the admin to one return, but it also makes every member jointly liable for the group's VAT debt and can blend partial exemption recovery across companies that were never meant to share it.
Read the article →Basis period reform pushed every unincorporated property trading business onto a tax-year basis from 2023/24, and the transition profit it created is still landing on tax returns years later. Who it actually catches, and what happened to old overlap relief.
Read the article →A planning refusal or a collapsed land deal doesn't automatically mean VAT already reclaimed on architects, agents and surveyors has to be repaid. What HMRC actually looks at when a development never gets built.
Read the article →A UK residential property sale with a taxable gain has to be reported to HMRC and the tax paid within 60 days of completion, not exchange — and non-residents must report every disposal of UK land within the same window regardless of gain, loss or relief.
Read the article →A block of flats over a ground-floor shop isn't one VAT answer, it's two, split between zero-rated residential construction and standard-rated commercial space. How the apportionment actually works, and where developers lose input VAT they didn't expect to.
Read the article →Buying several properties from the same seller, even across separate contracts and completion dates, can be a linked transaction for SDLT — taxed on the combined price, not each purchase separately. How the rules catch phased new-build purchases and portfolio deals.
Read the article →A developer who builds zero-rated new dwellings to sell, then decides to keep and let them instead, doesn't escape VAT by not selling — the self-supply charge taxes the change of intention itself.
Read the article →Siblings or partners who built a property portfolio together in one company often reach a point where they want to go separate ways without a forced sale. How a statutory demerger and a liquidation demerger split a company tax-efficiently, and why SDLT is usually the trap.
Read the article →Agricultural Property Relief only ever covers a field's agricultural value, never its development or hope value. How that gap opens the moment a developer comes calling, and why an unexercised option can widen it further.
Read the article →Selling part of a garden or field while keeping the rest is a part disposal, taxed on a different basis to a full sale. How the A/(A+B) apportionment formula works, when small part disposals relief defers the gain instead, and where Private Residence Relief stops helping.
Read the article →Multiple Dwellings Relief was abolished in June 2024, but a separate relief for annexes and granny flats is still alive: subsidiary dwelling relief from the 5% surcharge. The one-third value test, and why it's routinely confused with the relief that no longer exists.
Read the article →Student accommodation is zero-rated through a different route to ordinary housing: the relevant residential purpose test. The certificate that has to be in place before completion, what counts as non-qualifying use, and the change of use clawback that can bite years later.
Read the article →Capital expenditure over £250,000 on land, buildings or civil engineering works isn't a one-off VAT recovery. It's a ten-year standing obligation to keep testing how the building is used, and a change of tenant years later can trigger a real cash adjustment.
Read the article →Commercial leases are taxed twice for SDLT: once on the premium, once on the net present value of the rent. How the NPV calculation works, why turnover rent needs a five-year review, and why VAT on rent can quietly increase the bill.
Read the article →Councils across England can now charge up to 100% extra council tax on furnished second homes. Who the premium actually catches, the exemptions that matter, and why it isn't the same test as the one that ended favourable FHL tax treatment.
Read the article →A dilapidations payment, a surrender premium and a reverse premium are not the same thing for VAT, and HMRC's own position on dilapidations has shifted more than once. Where the current line sits, and why the option to tax decides the answer.
Read the article →A loss sitting in one property SPV does nothing for a profitable sister company unless the group actively surrenders it. The 75% group relief test, what property business losses qualify, and why this isn't the same as SDLT group relief.
Read the article →A portfolio mixing opted, taxable lettings with unopted, exempt ones can't recover all its input VAT automatically. How the standard method apportions residual VAT, the £625-a-month de minimis limit, and why the annual adjustment gets missed.
Read the article →Spend more than £3 million on construction operations in a rolling 12 months and a landlord, developer or housing association becomes a CIS deemed contractor, even though building isn't their business. What triggers it, and what registering involves.
Read the article →From 6 April 2026, 100% Business Property Relief is capped at £2.5 million, transferable between spouses. What changed since the original £1m proposal, who it actually affects, and why most rental portfolios are untouched.
Read the article →A company can sometimes sell shares in a subsidiary completely tax-free under SSE. Most property SPVs fail the trading test that makes this work — why letting companies fall short, and where the relief genuinely applies.
Read the article →Selling an opted commercial property with sitting tenants can be treated as a VAT-free transfer of a going concern, but the buyer's option to tax has to be in place and notified before completion. How TOGC works, and where it fails.
Read the article →Holiday lets are VAT-standard-rated like a hotel room, not exempt like a normal letting, and business rates now depend on actually letting a property 70 days a year since April 2023, not just intending to. What owners get wrong.
Read the article →Non-residents pay UK CGT on residential property since 2015, and on commercial property and property-rich company shares since 2019. The 60-day return, rebasing to April 2015 or 2019, and how it sits alongside the SDLT surcharge and rental income rules.
Read the article →Self-builders and barn converters can reclaim VAT on materials from HMRC even without being VAT registered. How the DIY Housebuilders Scheme works, what qualifies, and why the six-month claim deadline catches people out.
Read the article →Living in a property you renovate does not automatically make the gain tax-free. How PPR relief, the nine-month final exemption and Higgins v HMRC actually work — and why HMRC denies the relief entirely once a sale looks like a trade.
Read the article →A loss-making first year of development can generate a cash refund against your other income — but only if the activity is a genuine trade. How sideways relief, the £50,000/25% reliefs cap and the non-active partner restriction work.
Read the article →Genuine mixed-use property pays SDLT at non-residential rates on the whole price, with no surcharge. How HMRC tests a mixed-use claim after Hyman, Goodfellow and Averdieck, and where claims fall apart.
Read the article →Inheriting a property resets its CGT base cost to probate value. How rebasing, executors' allowances, joint beneficiaries and probate valuation disputes actually work when the property is later sold.
Read the article →Leave a loan from your property company outstanding nine months after the year end and it triggers a 33.75% Corporation Tax charge. How the charge, the refund and the bed-and-breakfasting rule actually work.
Read the article →Section 106 obligations are negotiated per site, not calculated by formula like CIL. How affordable housing contributions are treated as a cost of development, and the VAT position on transfers to registered providers.
Read the article →Non-UK residents pay an extra 2% SDLT surcharge on top of standard and additional-dwelling rates. How residence is tested, when the surcharges stack, and how to reclaim it.
Read the article →Running two or three property SPVs? The associated companies rule shares the 19% and 25% Corporation Tax thresholds across every company under common control, even if they never transact with each other.
Read the article →Offsite manufacture, novel structural systems and bespoke building physics work can qualify for R&D tax relief, but most property developers never claim. What genuinely counts, and the records HMRC expects.
Read the article →A lease extension premium is capital, not income, for the freeholder, and not usually a disposal at all for the leaseholder — but SDLT is still due on the premium, and enfranchisement is taxed differently again.
Read the article →Group relief removes SDLT on property transfers within a 75% group — but it's withdrawn if the transferee leaves within three years, and denied outright if that exit was already arranged at the time of transfer.
Read the article →RPDT charges 4% on UK residential development profits above a shared £25 million group allowance. Who counts as an RP developer, what falls outside the charge, and how the allowance splits across group companies.
Read the article →CIL is charged per square metre of net additional floorspace, but the self-build, charitable and social housing reliefs that make it manageable all depend on paperwork filed before work starts on site.
Read the article →A new floorspace-based charge lands on most residential development in England from 1 October 2026. How the rate is set, which schemes are exempt, and why the timing of a building control application now matters.
Read the article →An option premium is taxable the moment it lands, whether or not the sale ever completes. A promotion agreement is taxed very differently. How each structure is treated for CGT, SDLT and VAT, and how to choose between them.
Read the article →Landowner and developer, or two developers pooling capital. Whether the JV sits in an LLP or a company changes who pays tax, when, and what SDLT is due when the land goes in — including the mixed membership trap on corporate members.
Read the article →The void period on a vacant commercial unit runs out. A finished-but-unsold home can tip into the empty homes premium. What actually stays exempt, and when each charge kicks in during a project.
Read the article →Permitted development skips a planning hurdle, not a tax one. Why an office or barn bought for a Class MA or Class Q conversion is usually taxed as non-residential for SDLT, and why the VAT rate on the works is 5%, not zero.
Read the article →A bare land sale to a housing association is VAT exempt. Time the sale to complete after golden brick stage and it can be zero-rated instead — unlocking full input VAT recovery on build costs. How the structure works and where it fails.
Read the article →A FIC doesn't remove existing wealth from your estate on day one. What it does is redirect future growth in a portfolio outside your estate without a trust's periodic IHT charges — and where it falls short.
Read the article →Geared property groups can lose Corporation Tax relief on interest they've actually paid once net interest crosses £2m. How the fixed and group ratio methods work, and why related-party loans bring the threshold closer than expected.
Read the article →A property that is genuinely uninhabitable can be taxed as non-residential for SDLT — but HMRC has narrowed the test hard since P N Bewley. Where the line actually sits after Fiander, Brower and Mudan.
Read the article →Landlords who disclose undeclared rental income voluntarily get far better terms than landlords HMRC catches first. How the Let Property Campaign works, the penalty bands, and why data-matching usually gets there eventually.
Read the article →MDR was withdrawn for transactions from 1 June 2024. What the relief used to do, why HMRC scrapped it, the transitional rules, and the six-or-more-dwellings rate that still applies to genuine bulk purchases.
Read the article →Married couples who jointly own a rental property are taxed 50:50 by default, regardless of who actually owns what. A declaration of trust and Form 17 election can change that — but only in the right order.
Read the article →Separating spouses get up to three tax years to transfer property between them without a CGT charge, and transfers under a court order are exempt from SDLT — but timing decides which relief applies.
Read the article →A repair is deductible against rental income the year it's paid for; an improvement isn't. HMRC's tests for the difference, the pre-purchase repairs trap, and Replacement of Domestic Items Relief.
Read the article →Property sales, SDLT relief claims and rental income are among the most data-matched areas HMRC enquires into. What triggers a property tax enquiry, how the process works, and how to respond.
Read the article →Renovating an empty home, splitting a house into flats, or converting a non-residential building can qualify for 5% VAT instead of 20% — but only if the conditions and evidence are right before work starts.
Read the article →Overage lets a landowner share in a future planning uplift — but it creates two separate tax problems: when CGT is actually charged on the seller, and when SDLT falls due on the buyer.
Read the article →BADR can tax a company sale at 18% instead of standard CGT rates — but a genuine development company has to pass tests an investment-heavy portfolio usually fails.
Read the article →You incorporated to escape Section 24 — but the profit is now trapped in the company. Salary, dividends, directors' loans, pension contributions and MVL: how to get it out efficiently, and the traps in each route.
Read the article →A 150% Corporation Tax deduction on cleaning up contaminated or long-derelict land — plus a cash credit if the company is loss-making. Most eligible developers never claim it.
Read the article →Sell a renovated property and HMRC may tax it as trading income, not a capital gain — no annual exemption, no CGT rate, and Class 4 NIC on top. The nine "badges of trade" that decide which side of the line you're on.
Read the article →Gross payment status stops CIS tax being deducted at source, so subcontractors keep 100% of every payment instead of waiting a year for a refund. The turnover, business and compliance tests you need to pass.
Read the article →Incorporation relief can defer the CGT on moving a rental portfolio into a company — but only if HMRC accepts you're running a genuine business. What qualifies, what it doesn't cover, and the SDLT trap most owners miss.
Read the article →Rental property rarely qualifies for Business Property Relief, and gifting it usually triggers CGT with no certainty the IHT saving ever lands. What actually reduces the bill on a property portfolio.
Read the article →Every commercial property purchase splits into land, structure and fixtures for tax purposes. Why the Structures and Buildings Allowance, embedded fixtures and full expensing are usually worth far more than owners claim.
Read the article →Who the reverse charge applies to, the end user exclusion most businesses get wrong, and the cash-flow hit subcontractors feel once VAT is no longer collected on invoices.
Read the article →How the Non-Resident Landlords Scheme withholds tax on UK rental income, when to apply to receive rent gross, and the SDLT surcharge and CGT reporting rules that catch overseas investors off guard.
Read the article →ATED catches companies holding residential property above £500,000 — including SPVs set up after Section 24. Thresholds, reliefs, deadlines, and the trap of a director living in a company-owned home.
Read the article →The FHL regime ended on 6 April 2025. What owners lost — mortgage interest relief, capital allowances, CGT reliefs and pension treatment — and what's still worth checking a year on.
Read the article →MTD for Income Tax is now live for landlords over the £50,000 threshold, with £30,000 following in 2027. What qualifying income means, what quarterly updates involve, and what to do before you're mandated.
Read the article →Rates, the 60-day reporting deadline, Private Residence Relief, and the developer-vs-trading question that decides whether HMRC treats your profit as a gain at all.
Read the article →Why landlords can no longer deduct mortgage interest, who it hits hardest, and the incorporation, gearing and spousal-transfer options worth modelling before you decide.
Read the article →Now at 5% on top of standard rates, the additional dwellings surcharge adds a five-figure sum to most investment acquisitions. Who pays, when a refund is available, and what it means for companies.
Read the article →Stamp Duty is often the largest single tax cost on acquisition. A plain-English guide to Multiple Dwellings Relief, linked transactions, mixed-use and the planning that moves the bill.
Read the article →Where most money is either recovered or lost on a development project. Zero-rating new dwellings, the DIY housebuilder scheme, reduced-rate conversions and the option to tax.
Read the article →When does opting to tax pay off? A guide to the 20-year lock-in, TOGC, and the trade-offs between recovering input VAT and narrowing your tenant pool.
Read the article →Most subcontractors are owed money. What you can claim, how far back you can go, and the everyday situations where money is sitting with HMRC waiting to be reclaimed.
Read the article →SPVs are the default advice. Default is not always right. The tax, financing and admin trade-offs of using a Special Purpose Vehicle for a single project or a portfolio.
Read the article →Most accountancy is interchangeable; specialist tax is not. The case for a generalist, the cost of using one for specialist work, and the questions worth asking before you commit.
Read the article →Holding property in a company has become the default advice. It is sometimes right and sometimes expensive. Here is how to tell which.
Read the article →If you're weighing up a property decision and want a straight answer, that's exactly what we do. Ask us.
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