Property structure · Landlord guide · Updated May 2026
SPV vs personal name: which property structure is right for you?
Written by Iftikhar Rashid FCCA — Managing Partner, RR Accountants. 16 years in practice, specialist in property and landlord tax.
SPV vs personal name — the short answer
An SPV (limited company for property) avoids Section 24, allows full mortgage interest deduction, and pays corporation tax rather than income tax — typically more efficient for higher-rate landlords with mortgaged portfolios. However, transferring existing personally-held properties into an SPV triggers SDLT at full market value and CGT on any gain, often costing more than the ongoing tax saving. For new purchases, buying through an SPV is usually more efficient. For existing personally-held portfolios, the transfer economics must be modelled carefully for each property. We do not recommend either structure without running the specific numbers first.
Who this applies to: UK landlords with mortgaged residential property considering incorporation, or investors planning their first purchase.
SPV vs personal name — side by side
| Factor | Personal name | SPV (limited company) |
|---|---|---|
| Mortgage interest relief | 20% basic-rate tax credit only (Section 24) | Fully deductible as a business expense |
| Tax on profits | Income tax at marginal rate (20%–45%) | Corporation tax (19% on profits up to £50k, 25% on profits above £250k, 26.5% marginal between) |
| National Insurance on extraction | NI on salary drawn — not on rental profit itself | NI on salary drawn from the company |
| Profit retention | Taxed as it arises — cannot defer | Can retain profits within company at CT rates for reinvestment |
| SDLT on purchase | Standard residential rates + 5% additional-property surcharge | Standard residential rates + 5% additional-property surcharge |
| Transfer from personal to SPV | N/A | Triggers SDLT at market value + CGT on gain — often costly |
| Mortgage rates | Wider product range, lower rates typically | Higher rates (typically +0.2–0.7%), fewer products |
| Annual compliance | Self-assessment + SA105 property pages | Annual accounts + CT600 + director self-assessment |
| MTD Income Tax | Applies above £50k gross from April 2026 (£30k from April 2027, £20k from April 2028) | Not applicable — company follows CT rules |
| Inheritance planning | Property in estate at market value | Shares typically do NOT qualify for BPR where the SPV is an investment (buy-to-let) business; specialist advice required |
Sources: gov.uk/income-tax-rates, gov.uk/corporation-tax-rates, gov.uk/stamp-duty-land-tax. Take professional advice before making any decisions.
When each structure is typically more efficient
SPV is typically better when:
- ✓You are a higher or additional-rate taxpayer
- ✓You have significant mortgage interest (Section 24 impact is large)
- ✓You are buying new property — no transfer cost
- ✓You want to retain profits within the company for reinvestment
- ✓You have long-term portfolio growth plans, not imminent exit
- ✓You want to involve family members as shareholders
Personal name may be better when:
- →You are a basic-rate taxpayer (Section 24 impact is minimal)
- →Properties have large unrealised gains — transfer triggers significant CGT
- →You plan to sell within a few years (extraction adds complexity)
- →Mortgage-free or very low LTV — interest deduction less important
- →You want simplicity — one less set of accounts and filings
- →SPV mortgage rates wipe out the tax saving
Should I transfer existing properties into an SPV?
This decision is often irreversible.
Once you transfer a property into a limited company and pay the SDLT and CGT, you cannot undo it without triggering further tax charges. Model the numbers carefully — and factor in the full transfer cost before deciding.
The transfer triggers SDLT
SDLT is charged at full market value, not your original purchase price. For a property worth £500,000, SDLT at current rates including the 5% additional-property surcharge can be £25,000–£37,500+ depending on the rate band. See gov.uk/stamp-duty-land-tax.
The transfer triggers CGT
The transfer from you personally to your company is treated as a disposal at market value for CGT purposes. If you bought a property for £200,000 and it is now worth £400,000, you have a £200,000 gain — taxable at 24% for higher-rate taxpayers (18% basic-rate) on residential property.
Incorporation relief may not apply
Incorporation relief can defer CGT if the portfolio is run as a business. HMRC's test is strict — passive buy-to-let portfolios rarely qualify. Professional advice before transfer is essential.
The break-even calculation
For most landlords with substantial equity, the transfer costs exceed 5–10 years of Section 24 savings. The break-even point depends on portfolio size, equity, marginal tax rate, and mortgage interest. We calculate this for every client before recommending any transfer.
SPV vs personal name — frequently asked questions
What is an SPV in property?
An SPV (Special Purpose Vehicle) is a limited company created specifically to hold property. Unlike a general trading company, an SPV's sole purpose is to acquire, manage, and potentially sell investment property. Lenders, solicitors, and HMRC treat SPVs differently from personal ownership — they have their own tax rules, mortgage products, and compliance requirements.
Should I put my buy-to-let in a limited company?
It depends on your situation. An SPV avoids Section 24 (mortgage interest is fully deductible), pays corporation tax instead of income tax, and can retain profits within the company at lower rates. But if you already own properties personally, transferring them into a company triggers SDLT at full market value and potentially CGT on any gain — often making the transfer cost more than the tax saving. For new purchases, the SPV route is usually more efficient for higher-rate landlords. We model the specific numbers before recommending either structure.
What are the main advantages of an SPV for property?
Key advantages: (1) mortgage interest fully deductible — not subject to Section 24; (2) corporation tax rates on profit (19% on profits up to £50,000, 26.5% marginal between £50k–£250k, 25% above £250k) which may be lower than income tax for higher earners; (3) profits can be retained within the company and reinvested; (4) easier to bring in investors or co-directors; (5) potential inheritance tax planning benefits via shareholding (though BPR is not generally available on investment SPVs — specialist advice required). Disadvantages: higher mortgage rates on SPV products, additional admin (annual accounts, CT600), and difficulty extracting profits tax-efficiently.
What is the tax cost of transferring existing properties into an SPV?
Transferring personally-held property into a limited company triggers: (1) Stamp Duty Land Tax (SDLT) at the full rate on market value, including the 5% additional-property surcharge (post-October-2024 reform); (2) Capital Gains Tax on the gain since acquisition — even though no cash changes hands; (3) mortgage redemption and re-arrangement costs if the lender does not transfer. For most landlords with substantial equity, these costs exceed the Section 24 saving — making the transfer uneconomic.
Can I transfer my properties to an SPV without paying SDLT?
In limited circumstances, there are reliefs — for example, incorporation relief may apply if the property portfolio is run as a business (a 'trading' activity rather than passive investment). However, HMRC's test for this is strict, and most residential portfolios do not meet it. Partnership-to-company transfers also have specific rules. These are specialist planning areas. Do not attempt them without advice from a qualified tax adviser.
Are buy-to-let mortgage rates higher for SPVs?
Yes, typically. SPV buy-to-let mortgage rates are usually 0.2–0.7% higher than equivalent personal-name products, depending on lender and portfolio. The product range is also narrower. This increased cost must be factored into any SPV vs personal-name calculation — it can partially or fully offset the tax saving, especially for small portfolios.
Is it better to buy future properties in an SPV?
For higher-rate taxpayers buying new properties with mortgage finance, purchasing through an SPV is usually more tax-efficient from day one. There is no transfer event, no SDLT on a personal-to-company transfer, and the full Section 24 advantage applies from the first year. The decision rests on whether the higher mortgage rate and additional admin costs are offset by the tax saving at your marginal rate.
How do I extract money from an SPV?
The most common methods are: salary (deductible for the company, subject to income tax and NI for the director), dividends (taxed at 10.75% / 35.75% / 39.35% from 6 April 2026 — basic and higher rates rose by 2 points at the Autumn 2025 Budget — depending on band, no NI, requires distributable profits), director loans (must be repaid within 9 months of year-end to avoid the s455 tax charge, now 35.75% on loans made on or after 6 April 2026 / 33.75% on earlier loans), or leaving profit in the company to reinvest. The right extraction strategy is part of our annual review for every SPV client.
Related guides
- Section 24 explained — mortgage interest restriction
- Accountants for UK landlords and property investors
- Capital Gains Tax calculator
- Company formation — SPV setup
- MTD for landlords — complete guide
- Landlord accountant UK
SPV structuring
Want us to model SPV vs personal name for your specific portfolio?
We run the numbers on your properties, mortgage balances, equity, and marginal tax rate — and give you a clear answer on whether SPV makes sense and what the transfer cost would be.
Book a call →Iftikhar Rashid FCCA · 16 years · Specialist in property and landlord tax