22 Sep 2026 · 6 min read
SPV structures became popular after Section 24, but the landscape has changed. We look at whether limited company ownership still makes sense in 2026.
Section 24, phased in from 2017 and fully implemented by 2020, removed the ability for personal buy-to-let landlords to deduct mortgage interest from rental income before calculating tax. For higher-rate taxpayers, this dramatically increased their effective tax burden. Limited companies pay corporation tax on profit — historically at a lower rate than income tax — and can still deduct mortgage interest as a business expense. This made the SPV structure highly attractive to landlords building or refinancing portfolios.
Yes, in several ways. Corporation tax increased to 25% for profits over £250,000 in 2023, which reduced some of the tax efficiency at scale. However, rates for limited company mortgages have improved significantly as more specialist lenders have entered the market. The premium over personal BTL products has narrowed from 0.5–1% to closer to 0.2–0.4% in many cases. The calculation looks different in 2026 than it did in 2019, but for most higher-rate taxpayers, the structure still stacks up.
An SPV is a separate legal entity. It has its own bank account, files its own accounts, and comes with ongoing accountancy fees typically in the range of £1,000–£2,000 per year. Each property within the company requires a separate mortgage application. Not all lenders are comfortable with all SPV structures — trading companies (as opposed to purpose-built SPVs) require more specialist lenders and may attract slightly less competitive rates.
Almost always: it depends. If you're a higher-rate taxpayer with a long-term investment horizon and limited immediate need to extract profits, a limited company structure typically still makes sense. If you're a basic-rate taxpayer or planning to sell in the short term, the additional complexity may not justify the benefit. We work closely with your accountant to model both scenarios before making any recommendation. The right structure at the start can save tens of thousands over a portfolio's lifetime.
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BUY-TO-LET 15 Sep 2026 · 5 min read HMO Mortgages: What You Need to Know Before You Buy Read article
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