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Property118 arrangements not tax avoidance, Tribunal rules against HMRC

A Tribunal has ruled that Property118's Substantial Incorporation Structure (SIS) and Capital Account Restructure (CAR) arrangements were not tax avoidance products, contrary to HMRC's claims.

  • The Tribunal found that users of SIS had genuine commercial reasons for choosing its features, including obtaining full Incorporation Relief and avoiding refinancing.
  • The judgment stated that SIS could preserve full Incorporation Relief where refinancing might prevent it from being fully available.
  • HMRC's central case, which depended on presenting the arrangements as tax-driven, was deemed unsustainable by the Tribunal.

HMRC spent years fighting what it considered to be tax avoidance products offered by Property118, but a Tribunal has ruled against the tax authority. The Tribunal judgment in Property 118 Limited & Anor v HMRC [2026] UKFTT 1111 (TC) found that the Substantial Incorporation Structure (SIS) and Capital Account Restructure (CAR) were not tax avoidance products.

The Tribunal concluded that HMRC's central case, which argued that Property118's arrangements were tax-driven with commercial explanations as mere decoration, was unsustainable. This was after hearing evidence from landlords, accountants, solicitors, and mortgage professionals involved in the arrangements.

Landlords using SIS had two main reasons for their choices: to obtain full Incorporation Relief and to avoid refinancing at the point of incorporation for genuine commercial reasons. The Tribunal expressly found that SIS could preserve full Incorporation Relief in situations where refinancing might otherwise prevent it from being fully available.

The judgment also noted that Property118 did not invent concepts such as beneficial ownership, contractual indemnities, or the transfer of a business as a going concern. These were established concepts, with HMRC's own manuals and professional commentary recognising principles related to business liabilities and capital withdrawal before incorporation.

Why this matters: The Tribunal's findings confirm that SIS was not merely another route to the same result as a conventional incorporation involving new company borrowing, which is significant for the tax and legal professions.

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