Readers’ forum: Passing portfolio

My client is a successful housebuilder and property developer whose activities are carried on through a limited company in his sole ownership. Further he owns a very substantial property portfolio on which he pays income tax on the net rental income.

His existing borrowings are due to be repaid so that there will be no mortgage interest relief available in the future.

My client is contemplating renting all or part of his residential portfolio to his limited company which would in future be responsible for all outgoings such as insurance repairs and management.

My query concerns the level of rent that would be paid by the company to the client. Would this depend on the terms and length of any lease? He is aware that stamp duty land tax would be payable on the grant of a lease.

Our concern is whether...