Group Structuring
Services
When your portfolio outgrows a single company, the right group structure protects every asset, removes SDLT from intra-group transfers, and creates a clear route to growth, succession, and exit. We design and build it properly.
£2.4m+
Tax Saved for Clients
HMRC
Compliant
50+
Five-Star Reviews
Property
Tax EXPERTS
Fixed Fee
No hidden charges
75%+
Share HOLDING FOR GROUP STATUS
Who We Are
UK specialists in property group structuring and holding companies
As a property portfolio grows, a single-company structure often becomes inefficient, inflexible, and risky. A well-designed group structure with a holding company at the top and individual Special Purpose Vehicle subsidiaries beneath it provides powerful tax advantages. At UK Property Tax Accountants, we specialise in designing, implementing, and managing group structures for UK property businesses of every size.
SDLT group relief & CGT transfer planning included
HMRC clearance applications submitted on your behalf
Tax Advice & Planning
SDLT relief, CGT deferral and Corporation Tax savings
A properly constituted group unlocks three major tax advantages. Properties can be transferred between group companies without triggering SDLT, allowing portfolio reorganisation at no stamp duty cost. Within a 75% group, chargeable assets can be transferred between group companies on a no-gain/no-loss basis, deferring the CGT liability until the asset is sold outside the group. Group relief then allows a loss-making company to surrender losses to a profitable group member, reducing the overall Corporation Tax bill.
For SDLT group relief purposes, a group relationship is established when one company owns at least 75% of the ordinary share capital of another. The group relationship must be maintained for at least three years following an intra-group transfer for SDLT relief to be retained. We build safeguards against accidental degrouping charges into every structure we design, and we obtain advance HMRC clearances to provide written certainty before any transaction proceeds.
£0
SDLT on Qualifying Transfers
100%
Compliance Rate
Accounts & Compliance
Protect your assets and maximise sales value
Holding each property or project in a separate SPV means that the financial difficulties of one subsidiary cannot threaten the assets held by another. A group structure also creates flexibility at the point of exit. You can sell the shares in an individual SPV rather than the underlying property, which may allow the buyer to acquire the property without paying SDLT. We advise UK landlords, investors, and developers on designing and implementing group structures that are both tax-efficient and legally robust. From setting up SPVs and holding companies to planning your exit strategy, our specialists ensure your portfolio is structured to protect your assets, reduce your tax exposure, and position you for growth.
Common Pain Points
The Risks of Getting your Group Structure Wrong
A group structure that is poorly designed or incorrectly implemented can create significant unexpected tax charges. These are the most common pitfalls we identify and prevent for our clients.
Accidental Degrouping Charges
If a company that received an asset via a no-gain/no-loss intra-group transfer leaves the group within six years, a deemed disposal at market value is triggered. This degrouping charge can create a substantial unexpected CGT liability. We build structural safeguards to prevent inadvertent triggers.
Failure to Claim SDLT Group Relief
SDLT group relief is not granted automatically. It must be actively claimed in the SDLT1 return using the correct relief code. Failing to claim it, or claiming it incorrectly, results in SDLT being paid unnecessarily on intra-group transfers.
Incorrect Ownership Percentages
The group relationship for SDLT and CGT no-gain/no-loss transfers requires a 75% direct or indirect ownership threshold. Structures with 74% or below do not qualify. We verify ownership percentages at every level before any transfer is implemented.
Using a Group Structure When Unnecessary
A group structure introduces complexity, additional compliance costs, and intercompany documentation requirements. For smaller portfolios, the benefits may not outweigh the costs. We provide honest advice on whether a group structure is genuinely suitable for your portfolio.
Misaligned Accounting Periods
Aligning the accounting periods of all group companies is a requirement for certain group relief claims. Misaligned periods can mean losses cannot be surrendered as planned, resulting in higher Corporation Tax than anticipated.
Free No-Obligation Review
Let’s discuss your property accounting needs
Book a 30-minute consultation with a specialist. We’ll review your current structure and identify immediate opportunities.
- HMRC-compliant tax strategies
- Specialist UK property tax expertise
- Proactive planning, not just compliance
- Fixed-fee, no hidden charges
Our Services
Our Group Structuring Services
From initial structure design through to ongoing compliance for every entity in the group, we manage every aspect of your property group’s tax and accounting affairs.
Group Structure Design
We design a tailored group structure aligned with your commercial goals identifying the correct number of SPVs, the appropriate holding company arrangement, and any intercompany loan or dividend arrangements required.
Holding Company Formation
We register the holding company and any new SPV subsidiaries at Companies House, prepare bespoke Articles of Association, and manage all statutory filings and initial tax registrations.
HMRC Clearance Applications
For restructuring transactions involving CGT or SDLT reliefs, we prepare and submit advance clearance applications to HMRC, providing written certainty before any transaction proceeds.
Intra-Group SDLT Relief Claims
We prepare and file SDLT returns for all intra-group transfers, ensuring group relief is correctly claimed using the appropriate relief code and all conditions for retention of relief are documented and maintained.
Corporation Tax Group Returns
We prepare and file Corporation Tax returns for every entity in the group, calculate intercompany loss relief surrenders, and align accounting periods to maximise the group’s overall tax efficiency.
Group Restructuring Advisory
Where an existing portfolio of companies needs to be consolidated into a group, we identify the restructuring steps required, evaluate tax costs, manage HMRC clearances, and implement the full restructuring plan.
How It Works
Get started in four simple steps
Changing accountants should be smooth and simple, not disruptive and difficult. Our skilled property accountants help you with every step of changing service providers so that your record-keeping and tax compliance remain intact.
Free Consultation
Tailored Proposal
Smooth Handover
Ongoing Support
Why UK Property Tax Accountants
Why Property Investors choose UK Property Tax Accountants
That singular focus means deeper expertise in non-resident landlord taxation, faster answers on international treaty questions, and better outcomes for every overseas landlord we work with.
Dedicated Named Accountant
You will always work with a single, named Chartered Accountant who knows your companies, your portfolio and your goals intimately, not a call centre or a rotating team.
ACCA Registered Auditor
Registered as auditors in the United Kingdom by the Association of Chartered Certified Accountants, providing you with expert advice you can rely on and trust completely.
Transparent Fixed Fees
You will never receive an unexpected invoice. All fees are fixed, all-inclusive and agreed upfront, with no hourly rates and no extra charges for additional advice or HMRC queries.
Proactive Tax Reviews
We run quarterly tax reviews throughout the year, not just at year-end, so your corporate structure and tax position are constantly optimised as your portfolio evolves.
Cloud Accounting Technology
As Xero Platinum Partners and QuickBooks Pro Advisors, we provide real-time financial visibility across your portfolio, fully MTD-compliant and accessible anytime, anywhere.
Full Ecosystem of Services
Beyond accounting, we offer cashflow forecasting, legal referrals, commercial mortgage broker introductions and contractor insurance, providing a complete professional ecosystem for your property business.
Client Stories
What our clients say about us
★★★★★
“UK Property Tax Accountant Team saved me over £18,000 in CGT when I sold two properties last year. Their knowledge of available reliefs is extraordinary. I strongly recommend them. Unlike my previous accountant, they picked up the phone every time.”
★★★★★
“We restructured our entire portfolio into a limited company on their valuable advice. The tax savings pay for their fees many times over and every decision was explained clearly. Moving to them was the best decision we made for our property business.”
★★★★★
“As a property developer I deal with complex VAT, SDLT and CIS issues on every project. They handle everything seamlessly and their proactive advice has saved us significant six-figure sums. Switching from our old firm was completely painless.”
FAQS
Commonly Asked Questions about Group Structuring
Do group companies need to be UK-incorporated to benefit from SDLT group relief?
No. There is no requirement that group companies be incorporated or resident in the UK. Body corporates including companies incorporated overseas can form part of a qualifying group for SDLT group relief purposes, provided the 75% ownership threshold is met.
What happens if a company leaves the group within six years of an intra-group transfer?
A degrouping charge arises when a company that received an asset via a no-gain/no-loss intra-group transfer leaves the group within six years. The company is treated as having disposed of and immediately reacquired the asset at market value at the time of leaving the group, triggering a CGT liability. We build structural safeguards against this into every group we design.
Can UK Property Tax Accountants restructure our existing companies into a group?
Yes. We assess your existing companies, identify the restructuring steps required, evaluate any tax costs involved, manage all HMRC clearance applications, and implement the full restructuring plan from start to finish.
How long does it take to set up a group structure?
A straightforward holding company and SPV structure can typically be incorporated and fully operational within two to four weeks of instruction. Where HMRC advance clearance is required for example, for a transaction involving CGT group relief the clearance process takes up to 30 days, though in practice HMRC often responds more quickly. We provide a full timeline at the outset so you can plan your transactions accordingly.
Can I add my existing properties to a group structure after they have already been purchased?
Yes, but the process requires careful planning. Transferring properties already held by one company into a group structure involves a legal transfer and SDLT must be considered, although SDLT group relief may be available if the correct group relationship exists. CGT group relief may also apply on the intra-group transfer. We review the specific circumstances before recommending any transfer and obtain HMRC clearance where appropriate.
Still have questions?
Our property specialist accountants are ready to answer any questions about your specific tax situation with no obligation for an initial conversation.
- +44 121 262 1528
- Mon–Fri, 9am–5:30pm
Ready to get started?
Reduce your property tax bill
Book a free call with our property specialist accountant. We will review your structure and identify immediate savings opportunities.
- ACCA Registered
- Fixed Transparent Fees
- Onboarded Within 1 Week