Exit and Succession Tax Planning for Landlords

** Brand New Tax Saving Report Released - July 2026 **

Exit and Succession Tax Planning for Landlord

By Nick Wright BSc, CTA, FCA

Exit and succession planning is fast becoming the defining conversation many landlords have with their adviser. The generation that built its portfolios in the buy to let boom of the 2000s is now approaching retirement, and the question has shifted from acquiring the next property to leaving the ones already held. The structure adopted years ago now dictates every option that follows.

The risks have never been higher. The First tier Tribunal's ruling in SC Properties Ltd v HMRC has cast doubt on whether the partnership structures landlords rely on to cut stamp duty on incorporation will survive challenge. The Finance Act 2026 caps 100% business property relief at £2.5m per person from 6 April 2026. And from April 2027, property income will be taxed at rates two percentage points above earned income.

Get it right, and a landlord can freeze the value of a portfolio for the next generation and extract cash on the most efficient route available. Get it wrong, and clients face a dry capital gains charge with no cash to pay it, an unbudgeted stamp duty bill, a 40% inheritance tax charge, and advisers face the professional negligence claims that follow.

In this authoritative new guide, Chartered Accountant and Chartered Tax Adviser Nick Wright sets out exactly what every tax adviser needs to know to structure, execute and defend the exit or succession of a UK property portfolio.

This report will show you how to:

• Decide whether a client's goal is exit or succession, and why the two demand different structures
• Apply the trade versus business distinction that determines which reliefs survive
• Use incorporation relief and the sum of the lower proportions rule to cut the stamp duty cost
• Avoid the trap in SC Properties Ltd v HMRC, where partnership returns alone failed to prove a partnership existed
• Structure freezer and growth shares in a family investment company for succession
• Navigate the settlements legislation traps in alphabet share and family dividend arrangements
• Apply the April 2026 business property relief cap to mixed trading and investment estates
• Sidestep the phoenix TAAR when a company is liquidated and the owner keeps letting
• Choose between a capital reduction demerger and liquidation to divide a portfolio between family members
• Plus much more...

Who will benefit from this report?

This guide is essential reading for any accountant, tax adviser or solicitor advising landlords, family property portfolios or family investment companies, and for in-house tax professionals and property investors who need to understand the rules.

If you advise landlords on selling up, passing down or restructuring a property portfolio, this guide belongs on your shelf.

About the Author

Nick Wright BSc, CTA, FCA is a Chartered Accountant and Chartered Tax Adviser, and Director and Head of Corporate Tax at Jerroms Miller Specialist Tax. He is a regular contributor to Taxation magazine, Tax Journal, Tax Adviser, Tax Insider and ICAEW Taxline, and is a contributing author of Tolley Tax Planning, the Finance Act Handbook and British Tax Review.