Recently, there has been a lot of discussion about the use of hybrid or mixed LLP structures to hold property investments and avoid s24 interest expense restriction. HMRC issued Spotlight 63, stating that many of these structures may not be effective from a tax perspective and will need to be reviewed on a case-by-case basis.
Where are we now?
As far as “hybrid structures”, social media has gone quiet, and it is likely that many landlords could find themselves with an enquiry as HMRC digs through the thousands of cases to understand them and determine their effectiveness.
We support many clients with enquiries, and dealings with HMRC, and are discussing the implications and options available to several clients who have entered into structures to which they now believe Spotlight 63 may apply.
The next step
This is an excerpt from our latest issue of Prosper magazine. Read further to find out about the implications and options available for landlords. The full article can be accessed here.
