Moving properties into a company
Companies deduct interest in full. Incorporating can work well for higher-rate landlords, but capital gains tax and SDLT can arise on the transfer. See Incorporating a Property Portfolio.
Section 24
Section 24 stops individual landlords deducting mortgage interest from rental income. Instead you get a basic-rate tax credit, so higher-rate landlords pay tax on income they never really had. We show you what it's costing you, and the options that can bring that cost down.
Before April 2017, landlords deducted mortgage interest from rent like any other cost and paid tax on what was left. Section 24 (the finance cost restriction in section 272A of the Income Tax (Trading and Other Income) Act 2005) phased that out. Since 2020/21, no deduction is allowed for interest and other finance costs on residential lettings.
Instead you get a tax reduction at the basic rate: 20% for 2026/27. It's given on the lowest of your finance costs, your property profits and your taxable income above the personal allowance (excluding savings and dividends). Anything not relieved carries forward.
Companies are not affected. Nor are loans for commercial property.
Section 24 doesn't just cost higher-rate landlords money. It changes which band your income falls into.
Because taxable income is measured before interest, a landlord whose real profit sits comfortably in the basic rate band can find part of it taxed at 40%. That bigger number also drives your personal allowance taper, child benefit charge and, from April 2027, the new property income rates.
From 6 April 2027, rental profits in England, Wales and Northern Ireland are taxed at separate property income rates: 22%, 42% and 47%. The Section 24 credit rises with them, to the property basic rate of 22%.
The higher credit cancels out the rate rise on the interest itself, so most landlords pay around 2% more on their profit after interest. The gap between tax paid on interest and the credit stays at 20 points for higher-rate landlords and becomes 25 points for additional-rate landlords. Property income will also be taxed after your other income, so your allowances are used against salary or pensions first. Scotland and Wales will set their own property rates.
Companies deduct interest in full. Incorporating can work well for higher-rate landlords, but capital gains tax and SDLT can arise on the transfer. See Incorporating a Property Portfolio.
Keep what you have and grow inside a company, with full interest relief from day one. See buying property through a limited company.
Moving ownership to a spouse or civil partner with spare basic-rate band, recorded with a declaration of trust and a Form 17 sent within 60 days of signing.
Using cash or sale proceeds to repay borrowing removes the restricted interest. Simple, but it ties up capital and a sale can trigger capital gains tax.
A partnership doesn't escape Section 24 on its own, but on the right facts it can be a step towards incorporation with SDLT relief. HMRC scrutinises these closely.
Selling weaker, highly geared properties, or reshaping lending, can lift your after-tax return more than any structure.
Our free Section 24 calculator shows how much the restriction costs you in a minute, using current rates. Then talk to us: we'll model each option with your real figures, on a fixed fee agreed upfront, and we respond the same working day.
FAQs
You add back your mortgage interest and other finance costs, so you're taxed on the rental profit before interest. HMRC then gives a tax reduction equal to the basic rate on the lowest of three figures: your finance costs (plus any unused amount brought forward), your property profits for the year, and your taxable income above your personal allowance excluding savings and dividends. For 2026/27 the reduction is 20%. Anything that can't be relieved this year carries forward to the next.
No. Section 24 only restricts finance costs on loans that relate to residential lettings, which the legislation calls dwelling-related loans. Interest on a loan used for a shop, office or other commercial property let as part of your property business is still deducted in full when working out your profit. If a portfolio mixes residential and commercial property, the borrowing needs to be split sensibly between the two, and good records of what each loan funded make a real difference.
Often not directly, because a basic-rate taxpayer gets a 20% credit on interest that would otherwise have been relieved at 20%. The catch is band creep. Because the interest is added back, your taxable income rises and part of it can tip into the higher rate band. Landlords with large mortgages and modest rental margins are most exposed, sometimes paying higher-rate tax on income they never actually had in their pocket.
Yes, under the rules legislated in Finance Act 2026. From 6 April 2027, rental profits in England, Wales and Northern Ireland are taxed at new property rates of 22%, 42% and 47%, and the Section 24 credit is calculated at the property basic rate of 22% instead of 20%. The higher credit offsets the rate rise on the interest itself, so the extra tax is roughly 2% of your profit after interest.
Broadly, about 2% more on rental profit after interest. Take a higher-rate landlord with £50,000 of rent less expenses before interest and £20,000 of interest. In 2026/27 the bill on that income is 40% of £50,000 less a 20% credit on £20,000: £16,000. In 2027/28 it becomes 42% of £50,000 less a 22% credit on £20,000: £16,600. Real figures depend on your bands and other income.
It can. The personal allowance is reduced by £1 for every £2 of adjusted net income above £100,000 and disappears at £125,140. Because Section 24 adds your mortgage interest back into income, your adjusted net income can cross £100,000 even if your real profit is well below it. The effective tax rate in that band is very high, which is why landlords near the threshold should model their position each year.
It can do. The High Income Child Benefit Charge applies where adjusted net income is over £60,000, and the full benefit is clawed back at £80,000. Since Section 24 adds mortgage interest back into your income, rental profits can pull you over the threshold even though your cash income hasn't changed. Families claiming child benefit with a mortgaged portfolio should check where their adjusted net income really falls.
It isn't lost. If the credit is capped, for example because finance costs exceed your property profits or your taxable income is low, the unrelieved finance costs carry forward to later years with no time limit. They're added to the next year's finance costs when the credit is worked out. That carried-forward figure is worth tracking, because it has value if your rental profits rise or you restructure.
Yes. The restriction applies to individuals, including individuals in a partnership, and to trustees, personal representatives and beneficiaries of estates. Companies are the main exception. Trust and estate cases have their own rules for the tax reduction, so a portfolio held in a trust, or one being administered after a death, needs the calculation done carefully rather than assumed to work like a personal return.
No. Section 24 applies to individuals whether they let property alone or in partnership, so simply forming a partnership doesn't restore full interest relief. A genuine partnership can be useful in other ways, for example for flexible profit sharing or as part of a later move to a company, but it isn't a fix in itself. Be wary of schemes promising otherwise, as HMRC has challenged several.
Paying down debt removes the restricted interest, so it is the simplest fix, and it suits landlords with cash or properties they'd sell anyway. But capital tied up in a property earns only the rental yield, you may face early repayment charges, and selling to repay debt can trigger capital gains tax. It's worth comparing the after-tax saving on interest with what that money could earn or fund elsewhere.
Moving a share to a spouse or civil partner with spare basic-rate band can cut Section 24 tax. Transfers between spouses or civil partners living together are normally at no gain and no loss for capital gains tax, so the gain isn't triggered. Watch for SDLT where mortgage debt moves with the share, lender consent and the need for the beneficial ownership to be genuine.
Form 17 must reach HMRC within 60 days of the date the last spouse or civil partner signed it. HMRC applies that limit strictly and can't extend it. The new income split applies from the signature date, not earlier, so it can't be backdated. Form 17 only works where you genuinely own the property in unequal shares, usually evidenced by a declaration of trust, and the income split matches the ownership.
No. Joint tenants own the whole property together, not separate shares, so they can't declare unequal interests. Married couples and civil partners who own as joint tenants are taxed 50:50 on the income. To change that, you would first need to sever the joint tenancy so you hold as tenants in common, then record unequal shares, usually with a declaration of trust, before sending Form 17.
The restriction itself works the same way, but Scottish taxpayers pay Scottish income tax rates on rental profits, so the gap between the tax you pay on interest and the 20% credit can be wider. From April 2027 the Scottish Parliament and the Senedd can set their own property income rates, and the details for Scottish landlords were still to be confirmed at the time of writing. We'll check the current position for you.
Yes. Furnished holiday lets used to be outside Section 24, but the special regime was abolished from 6 April 2025 for income tax. Since then, finance costs on former holiday lets are restricted in the same way as other residential lettings, with only the basic-rate credit. Owners who relied on full interest relief for holiday lets often see a sharp rise in tax and should review their options.
Yes. Companies aren't affected by Section 24, so interest on a company's buy-to-let mortgage is deducted in full against its rental profits before corporation tax. That's why many growing landlords buy new properties through a company while keeping existing ones personally. The trade-offs are company mortgage terms, SDLT surcharges on every purchase, and tax when you take money out, so it's worth modelling first.
Related advice
Moving rental properties into a company: incorporation relief, the Ramsay business test, SDLT on market value, partnerships, lenders and ATED, explained.
Read moreBuying buy-to-let through a limited company or SPV: corporation tax, company mortgages, SDLT surcharges, getting profits out, and when it isn't worth it.
Read moreBuying more rental property? Personal or company ownership, joint ownership, refinancing, reinvesting profits and when to restructure your portfolio.
Read moreSpecialist tax advice for landlords with 3+ properties: Section 24, incorporation, property companies, CGT, SDLT and inheritance tax, on fixed fees.
Read moreA free first call with our team, then a fixed fee if you go ahead. We respond the same working day.
Or write to taxadvisory@aswatax.co.uk
