Why rising property values, HMRC compliance activity and the next ATED revaluation mean property companies should review their position now – ATED revaluation 2027

By Steve Bicknell FCMA, CGMA

If your limited company owns residential property, 1 April 2027 is a date worth putting in your diary now.

It is the next five-yearly Annual Tax on Enveloped Dwellings (ATED) revaluation date.

ATED broadly needs to be considered where companies and certain other non-natural persons own UK residential property worth more than:

£500,000

That threshold has applied for many years, while individual property values have continued to change.

A property that was comfortably below £500,000 at the previous 1 April 2022 valuation date could therefore be above it when revalued at 1 April 2027.

There is another potential trap.

Your company might have bought a tired residential property for £400,000 or £450,000 and subsequently extended and substantially improved it. It could now be worth £600,000.

Ordinary refurbishment of an existing dwelling does not normally create an immediate ATED valuation date merely because its market value has increased. The next five-year revaluation may therefore be the point at which that increased value brings the property into ATED.

Contrast that with a company buying an existing £600,000 dwelling today. Acquisition itself can create an ATED valuation date, so the company cannot simply wait until 2027.

And there is an equally important distinction:

Being within ATED doesn’t necessarily mean you have ATED to pay.

Commercial landlords, property developers and property traders may qualify for valuable ATED reliefs.

However:

£0 ATED to pay doesn’t necessarily mean £0 ATED compliance.

A Relief Declaration Return may still be required.

HMRC is also actively interested in whether companies claiming property rental business relief genuinely satisfy the commerciality and profit-seeking conditions.

More Tax on Companies owning High Value Residential Property – Steve J Bicknell Tel 01202 025252

ATED revaluation 2027 – Quick Answer

The next five-yearly ATED revaluation date is 1 April 2027.

Company-owned UK residential property should therefore be reviewed to establish its market value at that date.

A property previously below the £500,000 ATED threshold may be brought within the regime because its value has increased.

The existing 1 April 2022 valuation continues to apply through the 2027/28 ATED chargeable period, meaning that the 1 April 2027 valuation feeds into the next five-year cycle.

Importantly, a commercial landlord may qualify for Property Rental Business Relief, producing £0 ATED to pay, but that does not necessarily remove the requirement to submit an ATED Relief Declaration Return.

In short:

Property worth more than £500,000?

↓

CHECK ATED

↓

CHECK RELIEF

↓

CHECK RETURN

↓

£0 TAX ≠ £0 COMPLIANCE

What Is ATED?

ATED stands for:

Annual Tax on Enveloped Dwellings

It is an annual tax principally affecting higher-value UK residential property held within corporate and similar ownership structures.

Broadly, ATED should be considered where a UK residential dwelling valued above £500,000 is owned wholly or partly by:

• a company;
• a partnership containing a corporate member; or
• a collective investment scheme.

ATED operates by reference to individual single-dwelling interests, rather than simply looking at the company’s property portfolio as one asset.

The chargeable period runs from:

1 April to 31 March

The annual charge depends on the property’s ATED value band.

However, several important reliefs can potentially reduce that charge to nil.

Why Is 1 April 2027 So Important?

ATED operates using a five-yearly statutory revaluation cycle.

The key dates have been:

• 1 April 2012
• 1 April 2017
• 1 April 2022
• 1 April 2027

The 1 April 2022 valuation applies through the ATED period ending 31 March 2028.

The new 1 April 2027 value will therefore become relevant for the following five-year cycle.

This makes 2027 a particularly good year for property companies to identify residential assets that may be approaching the ATED threshold.

The £500,000 Problem

Let’s take a fictional example.

Bicknell Property Investments Limited owns a residential investment property.

Its ATED valuation at:

1 April 2022

was:

£450,000

It was therefore below the £500,000 threshold.

Since then, the company has:

• refurbished the property;
• installed a new kitchen;
• extended the building; and
• substantially improved its overall condition.

By:

1 April 2027

a professional valuation concludes that it is worth:

£575,000

The property has crossed the ATED threshold.

That potentially brings it within the ATED compliance regime when the new valuation becomes operative.

However, whether the company actually pays ATED is a different question.

Buying a Property Above £500,000 Is Different

You don’t always wait for the next five-year revaluation.

Suppose Bicknell Property Investments Limited purchases an existing residential property in October 2026 for:

£650,000

A property acquired after the previous five-year valuation date is valued by reference to its acquisition date.

ATED therefore needs to be considered at acquisition.

This makes ATED something that should be checked before or immediately after a company completes a residential purchase, rather than being discovered when the annual accounts are eventually prepared.

What If You Buy Below £500,000 and Do It Up?

Now suppose the company buys an existing property for:

£425,000

It spends £100,000 refurbishing and extending it.

After the work it is worth:

£600,000

That does not normally mean that completing ordinary improvement works automatically creates a new acquisition-style ATED valuation date.

So we potentially have two very different situations:

Company buys existing dwelling worth £600,000

Check ATED from acquisition.

Company buys existing dwelling for £425,000 and later improves it so it becomes worth £600,000

The next relevant five-year revaluation may be what brings it across the ATED threshold.

Separate rules can apply where works create a new dwelling, where interests are acquired or disposed of, or where other statutory valuation events occur.

ATED Uses Market Value – Not Simply Historic Cost

A common misconception is:

“The company only paid £400,000, therefore ATED can’t apply.”

That is not necessarily correct.

At a five-year revaluation date (ATED revaluation 2027) you need to consider the property’s market value at that date.

A property bought many years ago for £400,000 might now be worth £700,000.

Likewise, a substantial extension or redevelopment may have materially increased its value.

That is why properties previously valued around:

£400,000–£500,000

deserve particular attention ahead of the 2027 revaluation.

Property Rental Business Relief

Now for the good news.

Suppose your company owns a buy-to-let property worth:

£750,000

Does the company automatically have ATED to pay?

No.

Relief may be available where the property is used in a qualifying property rental business.

Broadly, HMRC’s guidance requires qualifying property to be let to a third party on a commercial basis and not occupied—or available for occupation—by someone connected with the owner.

A genuine commercial BTL could therefore produce:

ATED value: £750,000

Within ATED: Yes

Property Rental Business Relief: Potentially yes

ATED payable: £0

But the story doesn’t end there.

£0 ATED Doesn’t Necessarily Mean No Return

Where a relief reduces the ATED liability to nil, a company may still need to submit an:

ATED Relief Declaration Return

This is different from an exemption.

The distinction is extremely important:

EXEMPTION

Potentially:

No ATED + no ATED return

RELIEF

Potentially:

£0 ATED + return still required

HMRC specifically confirms that qualifying property rental businesses, developers and traders can claim relief, subject to their respective conditions.

HMRC Is Checking Property Rental Relief Claims

ATED should not be regarded as an obscure tax that HMRC rarely looks at.

HMRC has run a One-to-Many compliance campaign concerning higher-value residential property and qualifying property rental business relief.

The campaign has focused on companies owning UK residential property above the ATED threshold where historic tax filings indicated sustained rental losses or no taxable profit, and where companies had either claimed ATED property rental relief or had not filed ATED returns.

HMRC’s concern is straightforward.

Property rental relief requires the business to operate on a commercial basis and with a view to profit.

If a company’s tax filings show repeated losses, HMRC may ask whether those conditions were genuinely satisfied.

Importantly, a loss does not automatically mean relief is unavailable.

A genuine commercial property business can make losses.

But the company may need evidence showing that it was nevertheless operated commercially and with a genuine profit-seeking objective.

What Do HMRC’s ATED Letters Ask Companies to Do?

The One-to-Many campaign has asked affected businesses to review their ATED position.

Depending on the circumstances, companies may need to:

• provide HMRC with further evidence;
• submit outstanding ATED returns;
• correct earlier filings; or
• consider making a disclosure.

The campaign letters have generally required a response within 40 days.

HMRC has warned that failure to respond can result in it considering a discovery assessment, together with possible interest and penalties.

Bicknell Business Advisers’ Advice

If you receive an HMRC letter concerning ATED, do not respond by simply stating:

“We rented the property out, therefore the relief applies.”

Instead, establish whether you can evidence:

• genuine commercial letting;
• market rents;
• tenancy agreements;
• rent actually being collected;
• business plans and budgets;
• financing arrangements;
• attempts to achieve profitability;
• reasons for historic losses; and
• absence of connected-person occupation.

The quality of the evidence may become very important.

Received an HMRC ATED Letter?

If HMRC has contacted your company concerning:

• ATED Property Rental Business Relief;
• historic ATED returns;
• rental losses;
• whether your business was commercial;
• connected-person occupation;
• missing Relief Declaration Returns; or
• potentially late ATED returns,

take advice before responding.

The starting point should normally be to review:

VALUATIONS + CORPORATION TAX RETURNS + TENANCIES + ATED RETURNS + RELIEF CONDITIONS

together.

Depending on the circumstances, the right response may involve supplying evidence, correcting earlier returns or considering an appropriate disclosure.

ATED Penalties Can Apply Even Where the Tax Is £0

This is one of the most surprising aspects of ATED.

A company may genuinely qualify for a relief that reduces its ATED bill to:

£0

but still face penalties because the necessary return was filed late.

A Relief Declaration Return is still a tax return for penalty purposes.

HMRC’s current guidance expressly warns that penalties can apply where an ATED return or Relief Declaration Return is filed late.

Several tribunal cases demonstrate how seriously the filing requirement needs to be taken.

Conchri Investments Ltd – £15,700 of Penalties

One of the most useful recent examples is:

Conchri Investments Limited v HMRC [2025] UKFTT 600 (TC)

The company appealed ATED late-filing penalties totalling:

£15,700

One of its arguments was that it had been unaware of its ATED filing obligation and had not been told by either HMRC or its accountants that returns were required.

The tribunal’s decision contains several important lessons.

It noted that the statutory penalties can apply even where no ATED tax is due.

It also concluded that relying on an accountant did not automatically provide a reasonable excuse, and that HMRC has no obligation to notify a company that an ATED return needs to be filed.

The case also demonstrates why proper contemporaneous valuation evidence is important when arguing that a property was below an ATED threshold.

The practical message is simple:

Don’t wait for HMRC to tell you an ATED return is due.

Matrix Rental Ltd – Nil Relief Does Not Remove Penalties

In:

Matrix Rental Ltd v HMRC [2022] UKFTT 286 (TC)

a relief return was filed approximately 210 days late.

The company faced late-filing penalties even though the underlying activity was potentially ATED-relievable.

The tribunal rejected the company’s appeal against the remaining penalties and did not accept reliance on professional advisers as a sufficient excuse.

Again:

No ATED ultimately payable does not necessarily mean no late-filing penalty.

Priory London – Daily Penalties Can Be Retrospective

Some earlier ATED cases had questioned whether HMRC could impose daily penalties where the penalty notice was issued after the daily-penalty period had already begun.

That issue was resolved by the Upper Tribunal in:

Priory London Ltd / HMRC v Jocoguma Properties Ltd [2022] UKUT 225 (TCC)

The Upper Tribunal confirmed that HMRC can issue an ATED daily-penalty notice specifying an earlier start date.

HMRC subsequently highlighted the decision in its own Stamp Taxes newsletter.

In practical terms, companies should not assume that a historic filing failure can easily escape daily penalties because HMRC did not issue the notice in advance.

Property Developer Relief – Calling Yourself a Developer Isn’t Enough

ATED relief is also available in qualifying circumstances for:

Property developers

However, the relief depends on what the business is actually doing.

The case of:

Hopscotch Ltd v HMRC

is a useful warning.

The company had undertaken redevelopment work and argued that it was carrying on a property development trade.

The First-tier Tribunal disagreed, and the Upper Tribunal subsequently upheld the finding that a qualifying property development trade was not being carried on. ATED property developer relief was therefore unavailable.

This is an important reminder:

Property developer relief depends on substance, not description.

The fact that:

• your company has “property development” in its name;
• its SIC code refers to development; or
• building work has been undertaken

does not automatically establish a qualifying property development trade.

Evidence of the commercial activity and purpose matters.

Property Traders Can Also Qualify for Relief

There is also potential ATED relief where property is genuinely held as trading stock by a qualifying property trader for resale.

Again, contemporaneous evidence is useful:

• why was the property purchased?
• was it acquired for resale?
• how was it accounted for?
• was it actively marketed?
• was there private or investment use?

This links directly to our guide:

Property Investor or Property Trader? The 9 Factors HMRC Uses

The investment-versus-trading distinction can affect several different taxes.

ATED is another example.

What About HMOs?

HMOs deserve particular attention.

We’ve previously considered this in:

Are HMOs Within the Scope of ATED?

The planning, licensing or Council Tax description of a property does not necessarily determine its treatment for ATED.

The key is to identify the relevant single-dwelling interest.

Broadly, an HMO operating as one residence with shared facilities can produce a different result from a building containing genuinely separate, self-contained flats.

So don’t automatically assume:

“It’s an HMO, therefore ATED doesn’t apply.”

Check the physical and legal configuration of the property.

The Holiday Let and Connected-Person Trap

Suppose your company owns a holiday property worth:

£900,000

It is commercially let to holidaymakers throughout most of the year.

You assume Property Rental Business Relief applies.

Then the director and their family stay there for two weeks.

That can be a serious problem.

HMRC states that rental relief requires the property not to be occupied—or available for occupation—by anyone connected with the owner.

We’ve previously considered the wider consequences in:

Don’t Buy a Holiday Let in a Company If You Want to Stay in It

ATED provides another reason why personal occupation of company-owned residential property needs careful consideration.

What If the Connected Person Pays Market Rent?

Don’t assume charging a shareholder, director or relative market rent automatically solves the ATED problem.

Connected occupation can still prevent Property Rental Business Relief.

There may, however, be a separate question about whether an ATED charge that is actually paid is deductible in calculating the company’s taxable business profits where the expenditure satisfies the normal wholly and exclusively test.

The ATED relief question and the Corporation Tax deduction question are therefore not the same thing.

That distinction can be important where properties are commercially let to connected parties.

Borderline Valuation? Consider a Pre-Return Banding Check

The ATED revaluation 2027 is likely to create many borderline cases.

Imagine a valuer concludes that your property is worth:

£510,000

A relatively small difference in valuation could determine whether the property crosses the ATED threshold.

HMRC operates a:

Pre-Return Banding Check – PRBC

Where its conditions are satisfied, a PRBC may be available if the valuation is within 10% of an ATED band threshold.

For the £500,000 threshold, that means:

£450,000–£550,000

A PRBC is particularly relevant where genuine valuation uncertainty exists and the company is not claiming a relief that reduces the charge to nil.

Request it early.

It does not remove the obligation to deal with the ATED filing deadline.

Don’t Assume HMRC Will Tell You

This is worth repeating.

Imagine:

1 April 2022 valuation

£475,000

↓

1 April 2027 valuation- ATED revaluation 2027

£560,000

↓

Property enters the ATED value range

The company may never previously have filed an ATED return.

HMRC may not send a helpful letter saying:

“Welcome to ATED.”

The obligation is the company’s responsibility.

The tribunal’s comments in Conchri Investments reinforce precisely this point.

Keep Evidence of the Relief – Not Just the Return

An ATED return can be relatively straightforward to submit.

Proving several years later that the relief conditions were actually satisfied may be less straightforward.

Property companies should therefore retain appropriate evidence such as:

• professional valuations;
• valuation reports;
• tenancy agreements;
• evidence of market rent;
• records of rent paid;
• business plans;
• budgets and forecasts;
• explanations for loss-making years;
• board minutes;
• evidence of marketing;
• development plans;
• connected-person checks;
• PRBC correspondence; and
• copies of ATED filings.

HMRC’s One-to-Many campaign demonstrates why this matters.

The question may not simply be:

“Did you file a Relief Declaration Return?”

but:

“Can you demonstrate that you were actually entitled to the relief?”

Bicknell Property Investments Ltd – A 2027 Example

Let’s put this into a portfolio.

Bicknell Property Investments Limited owns four residential properties.

At 1 April 2022:

Property D was already within the ATED valuation range.

It is commercially let to an unconnected tenant, and the company has been submitting the appropriate ATED relief filings.

The other three properties were below £500,000.

Now fast-forward to:

1 April 2027

Professional valuations indicate:

Properties B and C have now crossed £500,000.

When the 2027 revaluation becomes applicable, these properties need to be brought into the company’s ATED review.

Assuming they continue to be commercially let to unconnected tenants and all relief conditions are met:

ATED payable may be £0.

But:

additional ATED Relief Declaration Return compliance may be required.

Property B also sits close enough to the £500,000 threshold that professional valuation evidence becomes particularly important.

That is the ATED revaluation 2027 trap in a nutshell.

Ten Questions Company Landlords Should Ask Before the 2027 Revaluation

1. What UK residential properties does the company own?

Prepare a complete schedule.

2. What was each property’s previous ATED value?

Don’t simply use the balance-sheet figure.

3. What was each property worth on 1 April 2027 – ATED revaluation 2027?

Pay particular attention to properties previously between £400,000 and £500,000.

4. Have we significantly improved any properties?

Their market values may have moved substantially.

5. Have we acquired £500,000+ dwellings since the previous revaluation?

They may already have triggered ATED obligations from acquisition.

6. Does a relief genuinely apply?

Consider rental business, development, trading and other statutory reliefs.

7. Can we evidence that the rental business is commercial and operated with a view to profit?

This is particularly important following HMRC’s compliance campaign.

8. Has anyone connected with the company occupied or had access to the property?

This could jeopardise relief.

9. Is the valuation close to a threshold?

Consider robust professional valuation evidence and potentially a PRBC.

10. Even if ATED payable is £0, has every required return been filed?

Never confuse:

£0 TAX

with:

NO RETURN

ATED 2027 – Frequently Asked Questions

When is the next ATED revaluation?

1 April 2027 – ATED revaluation 2027

Does the 2027 valuation immediately replace the existing valuation?

The existing 1 April 2022 valuation applies through the 2027/28 chargeable period. The 1 April 2027 valuation feeds into the next five-year cycle.

What is the ATED threshold?

Broadly, more than £500,000 for relevant company-owned UK residential dwelling interests.

Does a £750,000 company-owned BTL automatically mean ATED is payable?

No. Qualifying commercial rental businesses may claim relief.

If the relief makes ATED £0, can I ignore ATED?

No. A Relief Declaration Return may still be required.

Does making a rental loss automatically prevent Property Rental Business Relief?

No. But repeated losses can cause HMRC to examine whether the business is genuinely run commercially and with a view to profit.

Does renovating an existing property immediately revalue it for ATED?

Ordinary improvements do not themselves normally create an acquisition valuation date, although the increased market value may become relevant at the next five-year revaluation.

Will HMRC remind me if an ATED return is due?

Do not rely on it. The responsibility sits with the company.

Can penalties arise even when no ATED tax is payable?

Yes. Tribunal decisions have repeatedly demonstrated that late Relief Declaration Returns can still produce penalties.

What should I do if I receive an HMRC ATED compliance letter?

Review the position before replying and establish whether you can evidence the relief claimed. Professional advice may be appropriate before making a disclosure or correcting previous returns.

Bicknell Business Advisers’ Recommended ATED Review

We suggest the following process:

IDENTIFY → VALUE → CHECK → EVIDENCE → RELIEF → FILE

IDENTIFY

Identify all UK residential interests owned by the company.

VALUE

Establish the correct valuation date and market value.

CHECK

Determine whether the asset falls within ATED.

EVIDENCE

Make sure you can support:

• valuations;
• commercial letting;
• profit-seeking intention;
• development/trading status; and
• absence of disqualifying connected use.

RELIEF

Establish which relief or exemption applies.

FILE

Determine whether the company needs:

• a chargeable ATED return;
• a Relief Declaration Return; or
• no return because an exemption applies.

Bicknell Business Advisers’ Advice

The 2027 ATED revaluation should not be viewed simply as:

“Is the property worth more than £500,000?”

The better approach is:

VALUE → RELIEF → EVIDENCE → RETURN → TAX

For many genuine commercial property businesses:

ATED payable may ultimately be:

£0

But increasingly, the important questions are also:

Did you file the correct return?

and:

Can you prove that the relief conditions were satisfied?

HMRC’s compliance activity and the ATED tribunal cases demonstrate why those questions matter.

How We Can Help

At Bicknell Business Advisers, we specialise in advising landlords, property investors, developers and property companies.

We can help with:

• the 1 April 2027 ATED revaluation 2027;
• identifying properties newly brought within ATED;
• ATED Relief Declaration Returns;
• historic ATED compliance reviews;
• HMRC One-to-Many letters;
• Property Rental Business Relief;
• reviewing whether a rental business satisfies the commerciality and view-to-profit tests;
• property developer and trader reliefs;
• late ATED returns;
• penalty appeals and reasonable-excuse considerations;
• voluntary disclosures;
• connected-person occupation;
• company-owned holiday properties;
• HMOs and mixed-use property;
• Pre-Return Banding Checks; and
• working alongside professional property valuers.

If your company owns residential property worth around £500,000 or more, or you are concerned that previous ATED returns may not have been filed correctly, now is the time to review the position.

And if HMRC has already written to you about ATED:

Take advice before responding.

A historic ATED problem is generally easier to deal with proactively than after HMRC has raised assessments and penalties.

£0 ATED to pay doesn’t necessarily mean £0 ATED risk.

About the Author

Steve Bicknell FCMA, CGMA is Managing Director of Bicknell Business Advisers Limited, specialising in property taxation, landlord tax planning, SDLT, Capital Gains Tax and property company structures throughout the UK.

The New 22%, 42% and 47% Property Income Tax Rates Explained – Including Mortgage Interest Relief and Making Tax Digital

By Steve Bicknell FCMA, CGMA

Landlords are facing another significant tax change.

From 6 April 2027, property income will have its own separate Income Tax rates.

For landlords in England, Wales and Northern Ireland, the rates announced by the Government for 2027/28 are:

Each rate is therefore two percentage points higher than the corresponding current main Income Tax rate.

For a landlord with £30,000 of taxable rental profit, that could mean hundreds of pounds of additional tax every year.

For landlords with larger portfolios, the additional cost could run into thousands.

But there is an interesting twist.

The rate of Finance Cost Relief for residential mortgage interest will also increase from 20% to 22%.

And that’s not the only change arriving in April 2027.

The Making Tax Digital for Income Tax threshold falls from £50,000 to £30,000 at the same time, before dropping again to £20,000 from April 2028.

So April 2027 could mean:

higher tax + more landlords entering MTD + quarterly reporting + new mortgage interest calculations.

How much more could you pay?

And what should landlords be considering before the changes arrive?

Let’s take a closer look.

Why Are Property Tax Rates Changing?

Until now, property income has generally been taxed using the main Income Tax rates applying to non-savings, non-dividend income.

The Government is changing this by creating separate rates specifically for property income.

From 2027/28, these will be:

• 22% property basic rate
• 42% property higher rate
• 47% property additional rate

The new property rates take effect from 6 April 2027.

The Government has also confirmed that the Property Allowance and Rent a Room Scheme remain unchanged, while carried-forward property losses will continue to be set against property income.

How Much More Tax Could a Landlord Pay?

Let’s start with a simple example where there is no mortgage interest.

Suppose Sarah owns a buy-to-let property producing taxable rental profits of:

£25,000 per year

Assume all of that property income falls within her basic-rate band.

2026/27

£25,000 × 20% = £5,000

2027/28

£25,000 × 22% = £5,500

Extra tax: £500 per year

For every £10,000 of property income affected by the two-percentage-point increase, the additional Income Tax is potentially:

£200

So, ignoring allowances, finance costs and other complications:

The actual result depends on your other income, allowances, reliefs and which property tax bands apply.

Higher-Rate Landlords

Suppose David’s employment income already means that all his rental profits fall within the higher-rate band.

His property business produces:

£30,000 taxable profit

2026/27

£30,000 × 40% = £12,000

2027/28

£30,000 × 42% = £12,600

Extra tax: £600

The property additional rate similarly becomes 47%.

But for residential landlords with mortgages, that isn’t the end of the calculation.

What Happens to Mortgage Interest Relief?

This is where the new rules become particularly interesting.

Since the full introduction of the residential property finance-cost restriction—often referred to as Section 24—individual residential landlords have generally been unable to deduct mortgage interest from rental income when calculating taxable property profits.

Instead, qualifying residential finance costs can generate a basic-rate tax reduction.

Currently that relief is calculated at 20%.

From 6 April 2027, the Government has confirmed that Finance Cost Relief will instead be calculated using the new:

22% property basic rate

So property Income Tax rates are increasing—but the rate used for residential Finance Cost Relief is increasing too.

How Finance Cost Relief Works

Suppose a landlord has:

Rent: £40,000

Repairs, insurance, agent fees and other allowable expenses: £10,000

Mortgage interest: £10,000

For Income Tax purposes, the taxable property profit is broadly:

£40,000 rent

less £10,000 allowable non-finance expenses

=

£30,000 taxable property profit

The £10,000 residential mortgage interest isn’t simply deducted from that figure.

Instead, subject to the statutory restrictions, it generates a tax reduction.

Currently:

£10,000 × 20%

=

£2,000 Finance Cost Relief

From April 2027:

£10,000 × 22%

=

£2,200 Finance Cost Relief

So the landlord potentially receives an extra £200 of tax reduction.

But the property income itself is also being taxed at a higher rate.

Let’s put the two together.

Worked Example – Basic-Rate Landlord With a Mortgage

Assume:

Rental income: £40,000

Other allowable expenses: £10,000

Mortgage interest: £10,000

Taxable property profit: £30,000

For simplicity, assume all the property income falls within the property basic-rate band and the full Finance Cost Relief is available.

2026/27

Tax:

£30,000 × 20% = £6,000

Finance Cost Relief:

£10,000 × 20% = £2,000

Tax after Finance Cost Relief = £4,000

2027/28

Tax:

£30,000 × 22% = £6,600

Finance Cost Relief:

£10,000 × 22% = £2,200

Tax after Finance Cost Relief = £4,400

Additional tax from April 2027: £400

Notice something interesting?

The landlord’s economic profit before tax is:

£30,000 taxable property profit

less £10,000 mortgage interest

=

£20,000

And:

£20,000 × 2%

=

£400

The increased Finance Cost Relief therefore provides some compensation for the higher tax rate—but it doesn’t eliminate the increase.

Higher-Rate Landlord – Same Property

Now assume the same property is owned by a higher-rate taxpayer.

Again:

Taxable property profit: £30,000

Mortgage interest: £10,000

2026/27

£30,000 × 40% = £12,000

Less Finance Cost Relief:

£10,000 × 20% = £2,000

Tax = £10,000

2027/28

£30,000 × 42% = £12,600

Less Finance Cost Relief:

£10,000 × 22% = £2,200

Tax = £10,400

Again:

Additional tax = £400

So although the Finance Cost Relief rate rises to 22%, the landlord is still worse off.

Does This Reverse Section 24?

No.

This is important.

The Government is not abolishing Section 24.

Individual residential landlords will still generally calculate their taxable property profits without deducting residential finance costs.

Finance Cost Relief remains a tax reduction.

What changes from April 2027 is the rate used to calculate it:

20% → 22%

Section 24 therefore remains a major consideration for leveraged property investors.

Highly Geared Landlords Need to Be Careful

There is another complication.

Finance Cost Relief isn’t necessarily as simple as:

Mortgage interest × 22%

The amount eligible for the tax reduction can be restricted.

Broadly, the calculation takes account of qualifying finance costs, property business profits and adjusted total income.

Unused qualifying finance costs may potentially be carried forward.

This can be particularly important where:

• mortgage costs are high;
• property profits are low;
• a landlord has significant other reliefs;
• there are brought-forward finance costs; or
• overall taxable income is relatively low.

So don’t assume that every £10,000 of residential mortgage interest will automatically generate £2,200 of immediate tax reduction from April 2027.

Have You Remortgaged? There’s Another Interest Trap

There is another issue landlords shouldn’t overlook.

Not all interest necessarily qualifies for tax relief simply because the loan is secured against a rental property.

The purpose and amount of the borrowing can matter.

This can become particularly important where a landlord has:

• remortgaged a property;
• released equity;
• increased borrowing substantially;
• refinanced after the property increased in value; or
• used some of the additional borrowing for personal purposes.

Before calculating Finance Cost Relief at 22%, you first need to establish:

How much of the interest actually qualifies for relief?

A higher relief rate isn’t much help if part of the underlying finance cost doesn’t qualify in the first place.

We’ve previously examined this issue in:

Have You Remortgaged? Will That Restrict the Recovery of Interest Beyond the Section 24 Rules?

This is worth revisiting before April 2027 if your property borrowing has changed substantially since the property was acquired.

April 2027 Also Brings a Major MTD Change

The property tax increase isn’t the only reason landlords should have 6 April 2027 in their diaries.

Making Tax Digital for Income Tax is being introduced in stages.

This means thousands more landlords will be brought into MTD at exactly the same time as the new property tax rates begin.

The MTD Threshold Is Based on Income – Not Profit

This distinction is extremely important.

For MTD purposes, qualifying income broadly means your gross income from self-employment and property before expenses.

Suppose a landlord receives:

Gross rents: £36,000

Allowable property expenses: £12,000

Rental profit: £24,000

They might look at the £24,000 profit and conclude:

“I’m below the £30,000 MTD threshold.”

But their qualifying income could instead be:

£36,000

That could bring them within MTD from 6 April 2027.

And if a person has both self-employment and property income, the relevant qualifying income can include both.

What Will Landlords Have to Do Under MTD?

Landlords within Making Tax Digital for Income Tax will generally need to:

• keep digital records using compatible software;
• record property income and expenses digitally;
• send quarterly updates to HMRC using that software; and
• submit their tax return using compatible software.

So April 2027 isn’t simply about paying more tax.

For many landlords it will also mean more frequent reporting and a significant change to bookkeeping.

Bicknell Business Advisers’ Advice

If your gross property and qualifying self-employment income is approaching £30,000, don’t wait until April 2027.

Start preparing your bookkeeping and digital records now.

And even if you’re below £30,000, remember:

The threshold falls again to £20,000 from April 2028.

April 2027 – A Perfect Storm for Landlords?

Put the changes together and April 2027 starts to look much more significant.

Property Income Tax

20% → 22%

40% → 42%

45% → 47%

Residential Finance Cost Relief

20% → 22%

Making Tax Digital

Threshold:

£50,000 → £30,000

Then, from April 2028:

£30,000 → £20,000

For some landlords that means:

Higher tax + digital records + quarterly reporting

That’s why I think 2026/27 should be treated as a planning year.

Does This Make Property Companies More Attractive?

Potentially.

But the answer remains:

It depends.

The new 22%, 42% and 47% rates are Income Tax rates applicable to property income.

A property investment company is instead generally subject to Corporation Tax on its profits.

There is also an important financing difference.

The residential Finance Cost Relief restriction applies to individuals rather than companies.

A property investment company’s financing costs are instead dealt with under the Corporation Tax rules, including the loan relationship regime, subject to the relevant conditions and restrictions.

This can produce a very different result for a highly leveraged property portfolio.

But that doesn’t mean:

“Everyone should put their properties into a company.”

You also need to consider:

• Corporation Tax;
• tax when extracting profits;
• dividend tax;
• mortgage rates;
• SDLT;
• Capital Gains Tax;
• refinancing costs;
• inheritance planning; and
• your eventual exit strategy.

The April 2027 changes simply add another reason to run the numbers properly.

Another Potential Company Benefit – Qualifying Interest Relief

There is another financing opportunity property investors sometimes overlook.

Suppose you personally borrow money and then use those funds to make a qualifying investment in, or qualifying loan to, a property company.

Subject to the statutory conditions, qualifying loan interest relief may potentially be available against your personal income.

This is different from residential landlord Finance Cost Relief.

That can create an important distinction between:

Borrowing personally to own a residential investment property personally

and

Borrowing personally and using qualifying funds in a property company.

The tax treatment of the interest may be very different.

We’ve previously explored this in:

Are You Missing Out on Qualifying Interest Relief?

This is an area where the exact structure and use of the borrowed money matter, so advice should be taken before arranging the finance rather than trying to restructure it afterwards.

Married Couples – Could Ownership Become Even More Important?

Yes.

Suppose a married couple jointly own rental property.

One spouse is an additional-rate taxpayer.

The other has significant unused basic-rate band.

From April 2027, property income could potentially face rates of:

22%, 42% or 47%

The difference between the property basic rate and property additional rate is therefore:

25 percentage points

That makes the allocation of property income between spouses potentially even more important.

As we explain in:

How Landlords Can Legally Reduce Tax by Changing the Split of Rental Income

married couples and civil partners are generally taxed 50:50 on jointly owned property unless the conditions for an alternative treatment are satisfied.

Where there is genuine unequal beneficial ownership, Form 17 may allow the rental income to be taxed according to the actual beneficial interests.

But remember:

Form 17 doesn’t change ownership.

The underlying beneficial ownership must already support the unequal income allocation.

A Simple Husband and Wife Example

Suppose a jointly owned property generates:

£30,000 annual rental profit

One spouse’s share would otherwise fall within the 47% property additional rate.

The other spouse has sufficient capacity for the relevant income to fall within the 22% property basic rate.

The difference between those rates is substantial.

That doesn’t mean every married couple should immediately change their property ownership.

Changing beneficial ownership can have implications for:

• Capital Gains Tax;
• SDLT;
• Inheritance Tax;
• mortgage arrangements;
• entitlement to future sale proceeds; and
• estate planning.

But it does mean ownership should be reviewed rather than simply accepted because that’s how the property has always been held.

Former Furnished Holiday Let Owners Should Review Their Position Too

The special Furnished Holiday Letting regime was abolished from 6 April 2025.

Former FHL properties are now generally within the normal property income regime.

For qualifying residential property, this can mean the residential finance-cost restriction is now relevant.

For married couples and civil partners, the normal rules governing jointly owned property and Form 17 may also need consideration.

The April 2027 tax increase therefore provides another reason for former FHL owners to review their structure.

Another 2027 Change – How Allowances and Reliefs Are Used

There is another change that could easily be overlooked.

From April 2027, the Income Tax calculation rules are being changed so that certain reliefs and allowances will generally only be applied against property, savings and dividend income after being applied against other income.

This matters because property income will now have its own higher rates.

For taxpayers with several sources of income, the interaction between property income and other reliefs may therefore become more complicated.

This is another reason why looking only at the headline 22%, 42% and 47% rates doesn’t tell the whole story.

Nine Things Landlords Should Consider Before April 2027

1. Calculate the impact of the new rates

Work out what the 22%, 42% or 47% property tax rates could mean for your actual portfolio.

2. Review your Finance Cost Relief

Calculate the benefit of the new 22% rate—but first establish whether all your finance costs qualify.

3. Check historic remortgages

If you’ve released equity from rental properties or refinanced them, check whether all the resulting interest qualifies for relief.

4. Check your MTD qualifying income

Remember:

The threshold is based on qualifying gross income, not rental profit.

5. Get ready for quarterly reporting

If you’ll enter MTD from April 2027, put compatible software and digital bookkeeping in place beforehand.

6. Review jointly owned property

If property is owned between spouses or civil partners, consider whether the existing beneficial ownership remains appropriate.

7. Compare personal and company ownership

This is particularly important before purchasing your next property.

Moving existing properties can create significant tax and refinancing costs, whereas deciding how to structure a new purchase gives you much more flexibility.

8. Review how future purchases are financed

Don’t look only at where the property is held.

Consider:

• who should borrow;
• what the borrowing will fund;
• whether interest qualifies for relief; and
• whether alternative financing structures should be considered.

9. Review the whole portfolio

Property tax planning shouldn’t be done one property at a time.

Consider:

Ownership + Borrowing + Tax Rates + MTD + Future Purchases + Exit Strategy

together.

Is Buy-to-Let Still Worth It?

Whenever landlord taxes increase, the inevitable headlines appear:

“Buy-to-let is dead.”

That’s far too simplistic.

Property investment decisions should be based on:

• rental yield;
• financing costs;
• capital growth potential;
• tax;
• risk;
• leverage;
• cash flow; and
• long-term objectives.

But tax is undeniably becoming a larger part of the calculation.

A highly geared individual landlord paying 47% on property income while receiving a 22% tax reduction for qualifying residential finance costs has a very different cash-flow profile from a debt-free basic-rate landlord.

A property company can have a different profile again.

There is no single structure that is right for everybody.

Bicknell Business Advisers’ Advice

The April 2027 changes shouldn’t be viewed simply as:

“Landlord tax is going up by 2%.”

The real picture is considerably more interesting.

Landlords need to consider:

22%, 42% and 47% property Income Tax

• 22% Finance Cost Relief

• Section 24

• whether remortgage interest actually qualifies

• Making Tax Digital and quarterly reporting

• Form 17 and beneficial ownership

• personal versus company ownership

• how future acquisitions should be financed

For some landlords, the answer may simply be to budget for slightly more tax and get ready for MTD.

For others—particularly landlords with larger, highly geared portfolios—April 2027 provides a very good reason to review the entire structure.

Don’t wait until April 2027 to start planning.

Some changes involving ownership, mortgages or company structures can take time and may themselves have tax consequences.

The sensible approach is:

CALCULATE → REVIEW → PLAN → IMPLEMENT

before the new rules take effect.

How We Can Help

At Bicknell Business Advisers, we specialise in advising landlords, property investors, developers and property companies.

We can help with:

• calculating the impact of the new 22%, 42% and 47% property tax rates;
• Finance Cost Relief and mortgage interest;
• reviewing remortgaging and interest deductibility;
• Making Tax Digital for Income Tax;
• Form 17 and jointly owned property;
• beneficial ownership and Declarations of Trust;
• personal versus limited-company ownership;
• property incorporation;
• qualifying loan interest relief;
• Capital Gains Tax;
• SDLT; and
• former Furnished Holiday Lettings.

If you own rental property personally, 2026/27 is the ideal time to review how the April 2027 changes could affect you.

A two-percentage-point tax increase may not sound dramatic.

But when combined with Section 24, substantial mortgage borrowing, MTD and a larger property portfolio, the financial and administrative impact can become significant.

About the Author

Steve Bicknell FCMA, CGMA is Managing Director of Bicknell Business Advisers Limited, specialising in property taxation, landlord tax planning, SDLT, Capital Gains Tax and company structures for property investors throughout the UK.

Most property developers accept Stamp Duty Land Tax (SDLT) as simply another cost of doing business.

However, there is a little-known SDLT relief that, in the right circumstances, can save a property developer or property trading company many thousands of pounds.Property Investor or Property Trader? The 9 Factors HMRC Uses – Steve J Bicknell Tel 01202 025252

The relief isn’t widely understood, and many accountants, solicitors and developers are unaware that it even exists. Yet for developers involved in part-exchange schemes, chain-breaking transactions or acquiring residential properties in specific circumstances, it can make a substantial difference.

Even more interesting is the planning opportunity it can create for property development groups.

Let’s look at how it works.

What Is Property Trader Relief?

Property Trader Relief is a specialist SDLT relief contained in Schedule 6A Finance Act 2003.

It provides relief from SDLT where a qualifying property trader acquires a dwelling in one of several prescribed circumstances, provided all of the statutory conditions are satisfied.

Unlike many SDLT reliefs, this one is extremely targeted.

It is not available simply because you buy and sell residential property.

Who Can Claim the Relief?

This is one of the biggest misunderstandings.

Many developers describe themselves as property traders.

For SDLT purposes, that isn’t enough.

Generally, the relief is aimed at:

• Property development companies
• Corporate property traders
• LLPs carrying on qualifying trading activities
• Partnerships whose members are companies or LLPs

It does not normally apply to individuals, regardless of how many properties they renovate and sell.

When Does the Relief Apply?

The legislation covers several situations.

The most common are:

1. Part Exchange on a New Build

A developer sells a new house.

The purchaser cannot complete because they haven’t sold their existing home.

A qualifying property trader purchases that existing property, allowing the new-build purchase to proceed.

Provided the statutory conditions are met, SDLT relief may be available on the acquisition of the customer’s old home.

2. Saving a Broken Property Chain

Property chains collapse every day.

Where an agreed sale falls through, a qualifying property trader may purchase the individual’s existing home, allowing the onward purchase to complete.

Again, SDLT relief may be available if the legislative conditions are satisfied.

3. Buying from an Estate

Relief may also apply where a qualifying property trader acquires residential property from the personal representatives of a deceased individual.

4. Employment Relocation

Although less common, relief can also apply where a property is acquired as part of a qualifying employee relocation arrangement.

The Conditions Matter

This is not a relief that can simply be claimed because a company buys a house.

Several important conditions apply.

The Property Must Qualify

The seller’s occupation of the property and, where relevant, their intended occupation of the replacement property must satisfy the statutory residence conditions.

Watch the Refurbishment Budget

Many developers are surprised by this.

The legislation limits the amount that can be spent on refurbishment.

Broadly, the permitted amount is:

• £10,000, or
• 5% of the purchase price,

whichever is greater, subject to an overall maximum of £20,000.

Spend more than this and the relief may be withdrawn.

Don’t Let the Property

The legislation also restricts:

• granting leases or licences (other than limited statutory exceptions);
• occupation by directors, employees or connected persons.

These conditions are easy to overlook but can have expensive consequences.

A Planning Opportunity Many Developers Overlook

This is where things become particularly interesting.

Many property development groups separate their activities.

For example:

• one company undertakes developments;
• another company owns long-term investment properties;
• another company undertakes construction activities.

This raises an important question.

Can a development company acquire a property using Property Trader Relief and later transfer that property into another company within the same group to hold as a long-term investment?

In the right circumstances, this may be possible.

Property Trader Relief and SDLT Group Relief are separate reliefs.

Where the statutory conditions for both reliefs are satisfied, an intra-group transfer may qualify for Group Relief, potentially allowing the property to move into an investment company without creating a further SDLT charge.

For example, a development group might:

• acquire a customer’s property through its qualifying property trading company as part of a chain-breaking transaction;
• complete the development sale;
• decide that the acquired property represents an excellent long-term investment;
• transfer that property into a separate group investment company.

This can provide significant commercial flexibility for property groups that both develop and retain investment properties. Do you pay SDLT on Properties Transfers within a Group? – Steve J Bicknell Tel 01202 025252

However, great care is required.

The availability of both Property Trader Relief and Group Relief depends on the detailed facts, the statutory conditions and the wider SDLT anti-avoidance provisions.

This is not something to implement after completion—it should be considered before contracts are exchanged.

This is often where specialist advice can save clients significant amounts of tax.

Example

ABC Developments agrees to sell a newly built property to Mr Smith.

Unfortunately, Mr Smith’s purchaser withdraws shortly before exchange.

Rather than lose the sale, ABC’s property trading company purchases Mr Smith’s existing home.

Provided the acquisition satisfies the statutory conditions, Property Trader Relief may eliminate the SDLT that would otherwise arise on that purchase.

Several months later, ABC decides the property would make an excellent addition to its rental portfolio.

Rather than selling it immediately, the company explores whether it can transfer the property into its group investment company.

Where the conditions for SDLT Group Relief are also met, this may offer an efficient long-term ownership structure without an additional SDLT charge.

The key point is that this planning should be considered at the outset, not after the transaction has completed.

Common Mistakes

The most common errors include:

❌ Assuming all developers qualify.

❌ Believing buy-to-let companies automatically qualify.

❌ Exceeding the refurbishment limit.

❌ Letting the property.

❌ Missing the SDLT claim.

❌ Structuring group companies without considering how Property Trader Relief and Group Relief interact.

Why Professional Advice Can Save Thousands

Property Trader Relief is one of those areas where the tax legislation creates opportunities—but only if transactions are structured correctly from the beginning.

The timing of acquisitions, the identity of the purchaser, the intended use of the property and the ownership structure of the group can all influence whether relief is available.

A conversation before exchange of contracts can often identify planning opportunities that are no longer available once the deal has completed.

How We Can Help

At Bicknell Business Advisers, we work with:

• Property developers
• Housebuilders
• Construction companies
• Property investment groups
• Family property businesses

We regularly advise on:

• SDLT planning
• Development company structures
• Property investment companies
• Group reorganisations
• Incorporation
• Capital Gains Tax
• Corporation Tax planning

If you’re acquiring residential property through a company—or you’re considering retaining development properties as long-term investments—it’s worth taking advice before the transaction is finalised.

Quite often, a relatively straightforward restructuring or careful planning before contracts are exchanged can produce substantial SDLT savings.

If you’re unsure whether Property Trader Relief, Group Relief or another SDLT relief may apply, we’d be pleased to discuss your proposed transaction.

About the Author

Steve Bicknell FCMA, CGMA is Managing Director of Bicknell Business Advisers Limited, specialising in tax advice for property developers, landlords, investors and construction businesses. Steve advises clients throughout the UK on SDLT, Capital Gains Tax, company structures and property tax planning.