How Property Developers Can Zero-Rate the First Sale or Long Lease of a Qualifying Commercial-to-Residential Conversion

By Steve Bicknell FCMA, CGMA

You buy an old office building.

You convert it into residential flats.

The building work may qualify for 5% VAT.

But what happens when you sell the completed flats?

Many developers assume that the sale of residential property is simply VAT exempt.

That isn’t always correct.

Where a qualifying non-residential building has been converted into dwellings, the first qualifying sale or long lease by a person with the required person-converting status can potentially be zero-rated for VAT.

That distinction is extremely important.

Both an exempt sale and a zero-rated sale may involve £0 VAT being charged to the buyer.

However, a zero-rated sale is still a taxable supply, potentially allowing the developer to recover VAT incurred on the development.

An exempt sale generally restricts input VAT recovery.

This can make a substantial difference to the profitability of a residential conversion project.

The rules are contained in Schedule 8, Group 5 of the Value Added Tax Act 1994 and explained in HMRC VAT Notice 708.

Quick Answer – When Can a Converted Residential Property Be Sold at 0% VAT?

Broadly, the following conditions must be satisfied:

1. You grant a major interest in the building or relevant part.
2. The building has undergone a qualifying non-residential conversion.
3. The building has not been converted into a holiday home.
4. You have the required person-converting status.
5. It is your first qualifying grant of a major interest in the relevant building or part.
6. You hold a valid certificate where one is required.

For a qualifying long lease, zero-rating applies to the premium or, where no premium is payable, the first payment of rent. Subsequent rental payments are generally exempt.

The basic structure is:

NON-RESIDENTIAL BUILDING → QUALIFYING RESIDENTIAL CONVERSION → PERSON CONVERTING → FIRST MAJOR-INTEREST GRANT → 0% VAT

But each step matters.

A commercial-to-residential conversion does not automatically make the eventual sale zero-rated.

Why Zero-Rated Is Better Than Exempt for a Developer

This is the starting point.

Suppose a developer incurs £80,000 of input VAT on professional fees, legal costs, taxable building expenditure, marketing and other development costs.

If the completed property is sold zero-rated, the developer may be entitled to recover input VAT attributable to that taxable activity, subject to the normal rules.

If the property is sold exempt, input VAT attributable to the exempt activity is normally restricted.

	Zero-rated sale	Exempt sale
VAT charged to purchaser	0%	None
VAT classification	Taxable supply	Exempt supply
Input VAT recovery	Potentially recoverable	Normally restricted
Partial exemption	Depends on activities	Usually relevant

0% VAT is not the same as VAT exemption, even though the purchaser may pay no VAT in either case.

This is one of the most important distinctions in residential property development.

Worked Example – Office Converted Into Six Flats

Suppose Conversion Developments Ltd buys a redundant office building.

Development costs	Amount excluding VAT
Purchase price	£600,000
Conversion works	£400,000
Professional fees and other costs	£100,000
Total	£1,100,000

The company converts the office into six self-contained residential flats.

Each flat is sold for £250,000.

Total sales proceeds are therefore £1.5 million.

If the conversion satisfies the statutory requirements, the company has person-converting status and each sale represents its first qualifying grant of a major interest in that flat, the sales may be zero-rated.

For each flat:

Sale price: £250,000

VAT charged: £0

The sale nevertheless remains taxable at 0%.

This may allow the developer to recover qualifying input VAT incurred on the project.

However, not every development cost necessarily carries recoverable VAT. The VAT rate charged by suppliers, the nature of the expenditure and its attribution to taxable or exempt activities must all be considered.

What Is a Major Interest?

A major interest generally means a freehold or a sufficiently long lease.

The rules differ slightly across the UK.

Location	Qualifying major interest
England, Wales and Northern Ireland	Freehold or a lease for a term certain exceeding 21 years
Scotland	Owner’s estate or interest, or a tenant’s interest under a lease of at least 20 years

For example, granting a 999-year lease of a converted flat can constitute the grant of a major interest.

A normal six- or twelve-month residential tenancy does not.

What if the developer grants a long lease?

Where the first qualifying grant is a long lease, the zero-rating rules apply to the lease premium or, if there is no premium, the first rental payment.

Subsequent rental payments are generally exempt.

Therefore, developers should not assume that all payments under a qualifying long lease are zero-rated.

What Is a Qualifying Non-Residential Conversion?

Zero-rating does not apply merely because substantial refurbishment has taken place.

HMRC recognises two broad situations.

Situation 1 – The building has never previously been residential

The building or relevant part has not previously been used as a dwelling or for a relevant residential purpose.

Typical examples include:

• Office converted into flats.
• Shop converted into a dwelling.
• Warehouse converted into apartments.
• Redundant school converted into residential accommodation.
• Agricultural building converted into qualifying dwellings.

However, the building’s history and actual use must be checked.

A property being described as commercial, appearing on the business rates register or having commercial planning permission does not conclusively establish its VAT treatment.

Situation 2 – The 10-year rule

A building that has previously been used residentially can potentially qualify where it has not been used as a dwelling or for a relevant residential purpose during the 10 years immediately before the first qualifying sale or long lease.

This is particularly relevant to older buildings that were originally residential but have subsequently been used commercially.

For example, a former house may have been converted into offices many years ago.

The developer subsequently converts it back into flats.

If the relevant residential-use conditions are satisfied, the first qualifying major-interest grant may be zero-rated.

When does the 10-year period end?

This is an important technical distinction.

For the first major-interest grant following a qualifying non-residential conversion, the relevant 10-year test is measured by reference to the date of the sale or long lease.

It is not necessarily measured by reference to when conversion work starts.

HMRC acknowledges that conversion works can begin before the 10-year point is reached, provided the developer intends to make the qualifying disposal after that point and satisfies the other conditions.

There is a separate test for certain housing association conversions, where the relevant period is measured by reference to the commencement of conversion works.

The two rules should not be confused.

How do you prove the building has not been used residentially?

Developers should obtain evidence supporting the property’s history.

Useful evidence includes:

• Historic council tax and business rates records.
• Electoral register information.
• Utility records.
• Planning and building control documents.
• Previous leases.
• Historic photographs and floor plans.
• Correspondence from the local authority’s Empty Property Officer.

The distinction between residential and non-residential use can be particularly important where the building has been vacant, used for storage or occupied by property guardians.

Occasional residential occupation, including use as a second home, may prevent the 10-year condition from being satisfied.

This rule is different from the two-year empty-property rule, which can allow certain residential renovation works to qualify for 5% VAT.

See our earlier article: How Do You Get Zero VAT Using the 10-Year Rule?.

Mixed-Use Buildings – A Major VAT Trap

Mixed-use buildings create particular difficulties.

Suppose a developer purchases a two-storey public house.

The ground floor contains the bar and commercial areas.

The first floor contains the landlord’s residential accommodation.

The developer converts the building into two flats.

Example A – Separate conversion of commercial and residential areas

Flat 1 is created entirely from the former commercial bar.

Flat 2 is created from the existing residential accommodation.

The first qualifying sale of Flat 1 may be zero-rated.

The sale of Flat 2 would normally be exempt because it has been created from accommodation previously used residentially, unless another qualifying route applies.

Example B – Both flats include part of the original residential accommodation

Suppose the developer changes the layout so that each new flat incorporates part of the former commercial premises and part of the original residential accommodation.

Neither flat automatically qualifies for zero-rating.

This is because the qualifying conversion must be created from the non-residential parts of the building.

Simply creating additional dwellings does not guarantee zero-rating.

What does the case law say?

The Upper Tribunal considered this issue in:

Revenue and Customs Commissioners v Languard New Homes Ltd; DD & DM MacPherson v Revenue and Customs Commissioners [2017] UKUT 307 (TCC).

The decision confirmed that where newly created dwellings incorporated parts of pre-existing residential accommodation, the relevant first major-interest grants did not qualify for zero-rating merely because the development created additional dwellings.

The judgment is particularly relevant to conversions involving pubs, shops with accommodation above, guesthouses and other mixed-use buildings.

What if commercial units are retained?

Suppose an office building is converted into:

• Six residential flats.
• Two ground-floor commercial units.

The qualifying residential flats may be eligible for zero-rating on their first major-interest grants.

The commercial units remain subject to the normal VAT rules for land and buildings.

Depending on the circumstances, their disposal may be exempt or standard-rated.

A fair and reasonable apportionment may be necessary where costs or consideration relate to both qualifying residential and commercial parts.

What Does “Person Converting” Mean?

This is one of the most important technical conditions.

HMRC considers a person to have person-converting status where, in relation to the building, they have acted as a developer, contractor or subcontractor in carrying out the qualifying conversion.

For a typical developer, this includes someone who:

• Physically converts the building; or
• Commissions another person to undertake the physical conversion of a building in which the developer owns or holds an interest.

For example, Conversion Developments Ltd buys an office building and appoints contractors to convert it into flats.

The company may have person-converting status even though it does not physically carry out the construction work itself.

Simply purchasing a completed conversion does not normally confer person-converting status.

Development Company vs Investment Company – Why Structure Matters

Suppose Development Ltd buys an office block and commissions the conversion into ten flats.

After completion, the building is transferred to Investment Ltd.

Investment Ltd then grants long leases to purchasers.

Does Investment Ltd automatically inherit Development Ltd’s person-converting status?

No.

The normal rule is that person-converting status does not transfer merely because ownership of the property changes.

Investment Ltd may therefore be making exempt rather than zero-rated supplies.

That could have significant consequences for input VAT recovery.

However, there is an important exception involving qualifying transfers of a going concern.

Can Person-Converting Status Transfer Under a TOGC?

Yes, in certain circumstances.

This is an important exception to the general rule.

HMRC VAT Notice 708, paragraph 5.5.6, recognises that a purchaser acquiring a qualifying converted residential development as part of a transfer of a going concern (TOGC) can inherit person-converting status.

This can allow the purchaser to make a zero-rated first major-interest grant, provided the required conditions are satisfied.

Broadly, those conditions are:

1. A previous owner has not already made a relevant zero-rated grant of the converted building or part, disregarding the grant giving rise to the TOGC.
2. The purchaser would suffer an unfair VAT disadvantage if its first major-interest grants were treated as exempt.
3. Allowing the purchaser to make zero-rated supplies would not create an unfair VAT advantage.

Example – Group restructuring

Suppose Development Ltd has converted a commercial building into residential flats.

It proposes transferring its development business and property portfolio to an associated company as part of a genuine business restructuring.

The acquiring company will complete the first qualifying sales.

If the transfer qualifies as a TOGC and the conditions in paragraph 5.5.6 are satisfied, the acquiring company may inherit person-converting status.

HMRC recognises that denying zero-rating in such circumstances could create an unfair disadvantage, including input VAT restrictions or adjustments affecting development expenditure.

However, not every property transfer between companies qualifies as a TOGC.

A simple sale of a completed building does not automatically satisfy the rules.

The nature of the business transferred, the activities carried on by the purchaser and the detailed VAT conditions all need to be considered.

What if the purchaser completes the conversion?

There is another possible route.

Suppose a developer purchases a partly converted building and then commissions further qualifying conversion work.

That purchaser may acquire person-converting status in its own right.

In that situation, the purchaser is not necessarily relying on inheriting the seller’s status.

It may qualify because it has itself participated in the conversion.

For more information on TOGC requirements, see HMRC VAT Notice 700/9.

What About VAT Groups?

VAT groups have their own rules.

A transfer of a major interest between members of the same VAT group is generally disregarded for VAT purposes.

Therefore, an intra-group transfer does not normally use up the first qualifying major-interest grant.

However, this does not mean that every member of the VAT group automatically has person-converting status.

HMRC looks at the particular company actually making the external supply.

Example

Development Ltd and Investment Ltd are members of the same VAT group.

Development Ltd converts an office building into flats.

It transfers the completed building to Investment Ltd.

Investment Ltd then grants long leases to third-party purchasers.

Although the intra-group transfer is disregarded for VAT purposes, Investment Ltd does not automatically have person-converting status merely because Development Ltd carried out the conversion.

Unless Investment Ltd qualifies in its own right or under an applicable exception, its external grants may be exempt.

VAT grouping alone does not solve the person-converting problem.

This is why the company structure should be considered before the property is transferred.

What Does “First Grant” Actually Mean?

The zero rate generally applies to the qualifying person’s first grant of a major interest in the relevant building or part.

Importantly, the rules consider the grant made by that person.

An earlier sale by a different owner does not necessarily prevent another qualifying person from making a zero-rated first grant.

Similarly, selling one flat does not automatically use up the first-grant opportunity for every other flat in the building.

Example – Twelve flats

A developer converts an office block into twelve flats.

It grants a qualifying long lease of each flat to an individual purchaser.

Provided the relevant conditions are met, each first grant may be zero-rated.

The sale of Flat 1 does not prevent the qualifying first grant of Flat 2 from being zero-rated.

However, if the developer subsequently makes another grant of a major interest in Flat 1, that later grant would not ordinarily qualify for zero-rating under the same first-grant provisions.

What If the Developer Lets the Flats Before Selling?

This is a common practical problem.

Suppose a developer converts six flats intending to sell them.

The property market weakens.

Rather than selling immediately, the developer lets the flats on ordinary residential tenancies for twelve months.

Does that automatically prevent a future zero-rated sale?

Not necessarily.

An ordinary short residential tenancy is not itself a grant of a major interest.

Therefore, granting a short lease does not automatically use up the opportunity to make a later qualifying first major-interest grant.

However, there is another important issue.

Input VAT recovery

Residential letting is normally VAT exempt.

If the developer originally recovered VAT because it intended to make zero-rated sales, but subsequently uses the flats for exempt lettings, an input VAT adjustment may be required.

The outcome depends on the circumstances.

For example:

• A developer genuinely intends to sell and temporarily lets the flats while continuing to market them.
• A developer abandons the sales strategy and decides to retain the flats as a long-term rental investment.

These situations may have different input VAT consequences.

Evidence of the developer’s intentions is important.

This could include board minutes, marketing instructions, correspondence with estate agents and financial forecasts.

The future zero-rated sale may remain possible, but the intervening exempt rental activity can still create a VAT cost.

What If Some Flats Are Sold and Others Are Retained?

Suppose a developer converts ten flats.

Six are sold on qualifying zero-rated long leases.

Four are retained for long-term residential letting.

The developer now has both taxable and exempt activities.

Input VAT attributable to the qualifying zero-rated sales may be recoverable.

Input VAT attributable to exempt residential lettings will normally be restricted, subject to the partial exemption rules.

Shared costs may require apportionment.

Depending on the expenditure and circumstances, the Capital Goods Scheme may also apply.

From 29 July 2026, the expenditure threshold for new qualifying land and building assets entering the Capital Goods Scheme increased from £250,000 to £600,000 excluding VAT. Assets already within the scheme remain subject to their existing adjustment arrangements.

See HMRC’s guidance on the Capital Goods Scheme changes.

The VAT consequences should therefore be modelled before deciding which flats to sell and which to retain.

Holiday Homes and Serviced Apartments – Do They Qualify?

Not every property that looks like a dwelling qualifies for zero-rating.

The legislation specifically excludes certain holiday homes.

For these purposes, restrictions preventing a purchaser from occupying the property throughout the year or using it as a principal private residence can be particularly important.

For example, a converted apartment may be subject to a planning condition restricting occupation to holiday use.

The first sale or long lease may therefore be excluded from zero-rating.

The VAT treatment of holiday homes can be more complicated than ordinary residential disposals, including potentially standard-rated transactions.

Serviced apartments also require separate consideration.

The VAT treatment of short-stay accommodation services should not be confused with the VAT treatment of selling the underlying property.

What Makes a Property a Dwelling for VAT Purposes?

The property must satisfy the statutory requirements for being designed as a dwelling.

These include conditions relating to:

• Self-contained living accommodation.
• The absence of internal access to another dwelling.
• Separate use and disposal.
• Relevant planning permission.
• Legal restrictions affecting occupation or disposal.

Example – Flat tied to a business

Suppose a developer converts part of a commercial building into a self-contained flat.

However, a planning condition states that the flat can only be occupied by the manager of the adjoining business.

That restriction may prevent the property from qualifying as a dwelling for VAT purposes.

The issue is not simply whether the accommodation has a kitchen, bathroom and bedroom.

The legal restrictions on its use and disposal also matter.

Restrictions that merely limit the category of occupier may require a different analysis from restrictions tying the accommodation to a particular business or adjoining land.

Developers should therefore review planning conditions, Section 106 agreements, title covenants and other restrictions before assuming the property qualifies.

What About Garages, Parking Spaces and Communal Areas?

A qualifying first grant may also include certain associated land and facilities.

For example:

• The land on which the dwelling stands.
• A reasonable garden or surrounding plot.
• Certain parking rights.
• Qualifying garages intended to be occupied with the dwelling.

However, the extent of zero-rating depends on the circumstances.

A separately sold commercial unit or independent parking facility should not automatically be treated as zero-rated simply because it forms part of a residential development.

Where the disposal includes qualifying and non-qualifying elements, apportionment may be required.

Can a Partly Completed Conversion Be Sold Zero-Rated?

Potentially, yes.

HMRC recognises that the sale or long lease of a partly converted building may qualify where a real and meaningful start has been made on the conversion.

The work must go beyond simply securing or maintaining the existing structure.

This can be important where one developer begins a conversion and another acquires the property to finish it.

However, the transaction requires careful consideration of the building’s condition, the nature of the work undertaken and the person-converting requirements.

See our earlier article: Is There VAT on Part-Complete Conversions?.

How Does This Relate to 5% VAT on Conversion Works?

There are two separate VAT questions.

1. What VAT rate applies to the building work?

Certain qualifying residential conversion works may be eligible for the reduced rate of 5% VAT.

The rules depend on the type of conversion, the nature of the work and the statutory conditions.

2. What VAT rate applies when the completed property is sold?

The developer’s first qualifying major-interest grant may be zero-rated at 0% VAT.

It is therefore possible for a developer to receive qualifying construction services charged at 5% VAT and subsequently make zero-rated residential sales.

Where the development is intended to make taxable zero-rated supplies, the developer may be entitled to recover qualifying input VAT incurred on the conversion.

However, the construction VAT rate and the VAT treatment of the eventual disposal are separate matters.

See What Are the Practical Issues of Reduced VAT on Conversions?.

What About VAT1614D and the Option to Tax?

Another important consideration arises when purchasing the original commercial property.

Suppose a developer buys an office building from a seller who has opted to tax the property.

The seller may ordinarily charge 20% VAT.

However, where the purchaser intends to carry out a qualifying residential conversion, VAT1614D may allow the purchaser to disapply the seller’s option to tax in appropriate circumstances.

This can potentially make the acquisition exempt rather than standard-rated.

The timing of the certificate and the contractual arrangements are particularly important.

VAT1614D is separate from the rules allowing the developer’s eventual first qualifying major-interest grant to be zero-rated.

A developer therefore needs to consider both:

VAT ON THE ACQUISITION

and

VAT ON THE EVENTUAL SALE

The correct treatment at each stage can significantly affect cash flow, input VAT recovery and the overall cost of the development.

Ten Common Mistakes Developers Should Avoid

1. Assuming every commercial-to-residential conversion qualifies for zero-rating.
2. Treating zero-rated and exempt property sales as equivalent.
3. Applying the wrong 10-year test.
4. Ignoring historic residential accommodation in a mixed-use building.
5. Assuming that creating additional flats automatically qualifies the development.
6. Transferring a completed development between companies without reviewing person-converting status.
7. Assuming VAT grouping automatically transfers person-converting status.
8. Overlooking the specific TOGC exception in HMRC VAT Notice 708.
9. Ignoring input VAT adjustments when converted flats are let before sale.
10. Failing to review planning restrictions, certificates and the legal interests being granted.

Practical Checklist Before Selling Converted Residential Property

Before completing a disposal, the developer and advisers should establish:

• What was the building originally designed and used for?
• Has any part previously been used as residential accommodation?
• Does the conversion satisfy the non-residential conversion conditions?
• If relying on the 10-year rule, is there adequate evidence?
• Are the completed units qualifying dwellings?
• Do planning or title restrictions affect their status?
• Which company has person-converting status?
• Is the disposal that person’s first qualifying major-interest grant?
• Does the transaction involve a freehold or qualifying long lease?
• Has any previous letting affected input VAT recovery?
• Are any units being retained for exempt letting?
• Is there a VAT group or TOGC issue?
• Are certificates required?
• Does the Capital Goods Scheme apply?

Ideally, these matters should be reviewed before the development structure, financing and sales documentation are finalised.

Frequently Asked Questions

Can the first sale of a converted office building be zero-rated?

Yes, potentially. Where the building has undergone a qualifying non-residential conversion and the seller satisfies the person-converting and first-grant requirements, the sale may be zero-rated.

Is a 999-year lease a major interest?

Yes, a 999-year lease generally satisfies the duration requirement, although the other zero-rating conditions must also be met.

Can each converted flat be sold at 0% VAT?

Potentially. The first qualifying major-interest grant in each flat may be zero-rated, provided the relevant conditions are satisfied.

Can a former residential building qualify under the 10-year rule?

Yes, potentially. The building must satisfy the relevant historic-use conditions, including the absence of qualifying residential use during the applicable 10-year period.

Does renting a converted flat before selling it prevent zero-rating?

Not automatically. A normal short residential tenancy is not a major interest, but exempt rental activity can affect input VAT recovery.

Does person-converting status transfer between companies?

Not ordinarily. However, it may be inherited through a qualifying TOGC where the specific HMRC conditions are met.

Can a VAT group make a zero-rated first grant?

Yes, potentially. However, the member actually making the external grant must have person-converting status or qualify under an applicable exception.

Can the sale of a mixed-use conversion be partly zero-rated?

Yes, potentially. Qualifying residential parts may be zero-rated, while commercial or non-qualifying residential parts receive their appropriate VAT treatment. A fair and reasonable apportionment may be necessary.

Are holiday flats eligible for zero-rating?

Not automatically. Holiday-home restrictions can prevent zero-rating, and the transaction may be subject to different VAT treatment.

Can a partly completed conversion qualify?

Potentially. HMRC requires a real and meaningful start on the conversion, and the other statutory conditions must also be satisfied.

Final Thoughts

The first grant of a major interest rules can provide a substantial VAT advantage for property developers converting commercial buildings into residential accommodation.

However, the real benefit is often not the amount of VAT charged to the purchaser.

It is the developer’s ability to recover input VAT.

The outcome can depend on details that are easily overlooked:

• Whether the building was genuinely non-residential.
• Whether the developer has person-converting status.
• Whether the first qualifying major-interest grant has already occurred.
• Whether the flats are sold or retained for exempt letting.
• Whether company structures, TOGC arrangements and VAT grouping affect the position.
• Whether planning restrictions and legal documentation support the intended VAT treatment.

A VAT review at the acquisition and development-planning stages can help avoid expensive mistakes.

Bicknell Business Advisers Limited specialises in accounting and tax advice for property investors, developers and construction businesses.

If you are considering a commercial-to-residential conversion, it is worth reviewing the VAT treatment before finalising the development structure or committing to a sales strategy.

Related Reading

Start with our main commercial-to-residential VAT guide:

Commercial to Residential Conversion VAT – 5%, 0% or 20%?

Then see:

VAT1614D: Can You Disapply an Option to Tax When Converting Commercial Property to Residential?

Link to the published VAT1614D article.

Existing Articles

• Zero Rating Commercial Conversions – First Grant of a Major Interest
• Is There VAT on Part-Complete Conversions?
• What Are the Practical Issues of Reduced VAT on Conversions?
• When Do You Need a Certificate for 5% VAT on Building Work?
• What Are the VAT Implications of Converting Commercial Buildings to Residential?
• How Do You Get Zero VAT Using the 10-Year Rule?

Next in the Series

The 10-Year VAT Rule – When Can an Old Residential Building Become a Non-Residential Conversion?

Our next article will examine one of the most interesting and misunderstood VAT rules affecting residential conversions.

We will explore how the 10-year period is calculated, what constitutes residential use, how to demonstrate historic non-residential occupation and why the timing of the first sale or long lease can be critical to securing zero-rating.

HMRC Sources and Technical References

• HMRC VAT Notice 708 – Buildings and Construction – particularly section 5 on zero-rating following non-residential conversions.
• HMRC Construction Manual – Basic Conditions for Zero-Rating.
• HMRC VAT Notice 700/9 – Transfer of a Business as a Going Concern.
• HMRC VAT Notice 706 – Partial Exemption.
• HMRC VAT Notice 742A – Opting to Tax Land and Buildings.
• HMRC – Changes to the Capital Goods Scheme.

Relevant legislation: Value Added Tax Act 1994, Schedule 8, Group 5.

Relevant case law: Revenue and Customs Commissioners v Languard New Homes Ltd; DD & DM MacPherson v Revenue and Customs Commissioners [2017] UKUT 307 (TCC).

This article provides general information on UK VAT rules as at October 2026. The VAT treatment of an individual development depends on its specific circumstances. Professional advice should be obtained before transactions are completed.

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.