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Promoters of the “beneficial interest company trust” are capitalising on a trend among landlords to move existing properties into company structures. This allows them to avoid the higher buy-to-let tax being introduced next April, which at the moment relates only to properties directly owned by individuals.
Around 40 landlords have already used the loophole, promoted by law firm Cotswold Barristers. How does it work? Many existing landlords are deterred from “incorporating” their properties because of the costs associated with moving them into a company. One of these is the need to remortgage, which incurs administrative costs and may mean a borrower loses an extremely favourable low tracker rate. Landlords who own their properties themselves will have mortgages in their own name. If they move them to a company, they would have to take out a new mortgage via the company.
This may mean losing a favourable rate and moving onto a more expensive one. The “beneneficial interest company trust” claims to allow borrowers to move their properties into a company while retaining the legal title – removing the need to remortgage. Borrowers transfer solely the beneficial interest into the company, and keep the mortgage in their own names.
Buy-to-let tax changes Mortgage interest relief Meanwhile, income from the properties goes into the company and is taxed at the corporation tax rate, which is currently 20pc and falling, regardless of the tax band of the individual landlord. The landlord would still potentially have to pay stamp duty and capital gains tax on incorporation, unless they are exempt. An exemption from having to pay stamp duty exists for partnerships, and capital gains tax does not have to be paid by landlords who can show that they operate as a business.
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