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HMRC Spotlight 63 – a buy to let tax arrangement

Landlords beware

Key points

  • Changes of the past years have caused problems for buy-to-let owners.
  • HMRC Spotlight 63 warns landlords about arrangements it considers do not work.
  • Potential problems with mortgage lenders.
  • Landlords are looking for ways to mitigate their tax liability.
  • Some of the structures offered have significant technical weaknesses.

Hundreds of buy-to-let (BTL) individual landlords have landed in very hot water with HMRC announcing that a specific ‘hybrid’ limited liability partnership (LLP)-corporate partner structure is a ‘tax scheme’ in Spotlight 63 (

This crystallises a concern that many Taxation readers will have come across in the past few years on potential solutions that their landlord clients have found in the marketplace. These generally promise a fix to the mortgage interest relief issue for those landlords that cannot undertake a ‘normal’ incorporation of their BTL portfolio. The solutions will vary though will...

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