For an overseas investor, there is no universal rule that a buy-to-let limited company is better than personal ownership. A company can obtain corporation tax relief for qualifying mortgage interest, while an individual residential landlord currently receives a basic-rate tax reduction instead of deducting finance costs from rental profits. From 6 April 2027, the new property income rates will be 22%, 42% and 47%, with residential finance-cost relief calculated at the 22% property basic rate.

Companies currently pay corporation tax at 19% where qualifying profits are £50,000 or less and 25% above £250,000, with marginal relief between those limits. The thresholds are reduced where there are associated companies, so a growing group can reach the higher effective rate sooner.

Purchase tax, financing, how profits will be extracted and your longer-term residence plans can all change the answer.

The comparison in short

	Personal name	Limited company
Mortgage interest	Basic-rate tax reduction; 22% property-rate relief from April 2027	Relief generally available under corporation tax loan-relationship rules
Tax on rental profits	Property income rates of 22%, 42% or 47% from April 2027	19% small-profits rate, marginal relief, or 25% main rate
SDLT on an investment property	Residential bands, normally plus 5% if it is an additional dwelling and 2% for a non-resident transaction	Higher residential rates normally apply; 2% non-resident surcharge may also apply
17% corporate SDLT rate above £500,000	Not applicable	Can apply, but qualifying commercial property-rental purchases can obtain relief from it
Annual charge	No ATED	ATED may apply above £500,000, although qualifying commercial letting can obtain relief
Extracting cash	Rental profits belong directly to you	Taking profits out can create additional tax consequences
Mortgage market	Often broader	Specialist company and overseas-investor lending is commonly required

The SDLT point needs to be understood properly

A company purchasing a dwelling for more than £500,000 can, in some circumstances, face the 17% single SDLT rate on the whole price, increased to 19% where the 2% non-resident surcharge applies.

But that is not normally the rate for a genuine commercial buy-to-let company. HMRC provides relief from the 17% rate where the property is acquired exclusively for use in a qualifying property rental business carried on commercially with a view to profit. In that case, the company normally pays the higher residential SDLT rates instead, with the additional 2% surcharge where the transaction meets the non-resident rules.

That removes the simple £500,000 “crossover” suggested by the headline rate.

For example, a company buying a £1 million dwelling for a qualifying rental business does not automatically pay £170,000 of SDLT. Under the current higher residential bands it would pay £90,000 before the non-resident surcharge, or £110,000 if the additional 2% applies. An individual non-resident buyer who already owns another dwelling can face the same £110,000 banded charge. An individual who does not trigger the additional-dwelling rates may pay less.

The 17% rate remains important where the statutory relief is unavailable or later withdrawn, so the intended use and ownership arrangements must be reviewed before completion. Current calculations and conditions are on the GOV.UK stamp duty pages.

Where the company advantage can still sit

For a highly geared portfolio, company ownership can remain attractive because the restriction on residential finance-cost relief does not apply to companies in the same way it applies to individuals. A non-resident company earning UK property income has also been within corporation tax since April 2020.

That does not mean 19% is the final tax cost. Corporation tax can rise towards 25%, associated-company rules can reduce the thresholds, and taking profits out of the company may create tax in the shareholder’s country of residence. Administration, accountancy and mortgage pricing also belong in the calculation.

For non-resident buyers, our guide to mortgage readiness for overseas property investors explains why lender criteria can differ substantially from those available to UK-resident individual landlords.

The annual charge people forget

A company holding UK residential property worth more than £500,000 can fall within the Annual Tax on Enveloped Dwellings regime. Relief is generally available where the property is commercially let to an unconnected third party and the statutory conditions are met, but an annual Relief Declaration Return is still normally required.

For 2026/27, ATED charges range from £4,600 for properties valued at more than £500,000 up to £1 million, to £303,450 for properties worth more than £20 million where no relief applies. The current bands and filing rules are in HMRC guidance.

What a company does not solve

UK residential property has remained within the scope of UK inheritance tax since April 2017 even where it is held indirectly through certain offshore companies or partnerships. From 6 April 2025, the wider inheritance-tax regime also moved from domicile-based rules to long-term UK residence rules for overseas assets.

If you spend significant time in Britain, our note on day counting and tax residency explains why residence history needs to be considered alongside the property structure.

Moving an existing personally owned property into a company is also not simply an administrative transfer. It can be a disposal for capital gains tax purposes and a new acquisition for SDLT. Incorporation Relief can sometimes defer gains where a genuine business is transferred to a company in return for shares, but whether a property activity qualifies depends on the facts and level of business activity. Advice should be taken before restructuring an existing portfolio.

If you might move to the UK

Becoming UK resident can change the taxation of your wider income and assets, so residence planning should be considered alongside ownership structure. Separately, the High Value Council Tax Surcharge is due from April 2028 for residential property in England valued at £2 million or more on the government’s 2026 valuation basis. Published rates start at £2,500 a year and rise to £7,500 for properties worth £5 million or more, although detailed treatment of companies, trusts and other complex ownership structures has been subject to consultation.

If you are comparing jurisdictions, the Italy investor visa provides an investment-based residence route, while the Hungary golden visa currently includes qualifying investment-fund and donation routes. Greek residence routes can include qualifying real-estate investment, and our guide to buying Greek property as a UK resident covers the property side.

St Lucia citizenship by investment sits in a different category, as our comparison of residency and citizenship by investment explains.

For those considering a UK move, our articles on the shift to ten year settlement, the 2026 immigration rule changes and the proposed new investor visa provide wider immigration context. The government’s earned-settlement proposals remain part of an evolving immigration framework rather than a blanket ten-year rule already applying to every route.

Next steps

Run the numbers using the actual purchase price, borrowing, expected rental profit, ownership structure and intended holding period before exchange. Changing ownership later can create substantial tax and transaction costs.

Speak to our team about how your UK property plans fit alongside your residence, tax and immigration position.