Timing A few years back I posted on this subject and talked about "kairos" - the Greek word signifying the opportune, decisive or critical moment. Also in 2023 there was the beginning of an attack on limited liability partnerships [LLPs] Spotlight 63 was the result. If you are unaware of its content it dealt with those who transfer property into an LLP believing it avoids capital gains tax [CGT] - for those who set up an LLP in this way and did not pay CGT there was an opportunity to come forward and self declare. It was also an opportune time for many professional firms to line up, point out that " they had known all along" that LLPs were a form of tax avoidance and of course to attract new clients. Kairos. The fact that most LLPs have been set up on the basis that there is no transfer of legal title - personal ownership remaining personal - has got lost along the way. Earlier this month - April - the new format for "incorporation" came in; vastly different to the previous process and now with a high degree of threat - if the individual fails to meet the requirements, the tax office can treat the application as a disposal and charge CGT on the entire value of the portfolio. 4 weeks later - Spotlight 63 is re-introduced as Spotlight 63a. Tomorrow - 1 May - The Renters Rights Act 2026 becomes law. Is there a pattern developing? Kairos. The unchanged bank base rate today might be the only, temporary 'good' news in a world where landlords continue to be fair game. LLP/Company/QNUPS [pension accepting residential property] or a combination of two or more - if established strictly within the rules and regulations - by a qualified specialist - there are no loopholes. That's the point.

Posted by Chris Haley at 2026-04-30 13:40:00 UTC