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Will letting and sub-letting result in a lower tax bracket?

Question:

My daughter owns outright and rents out a house. She is in the higher tax bracket. Can she let it to me at low rent, and can I then sub-let it at market rent, thus moving the income into the lower tax bracket? 

Arthur Weller replies: 

Strictly speaking, this is permitted. However, if HMRC discovered the connection between your daughter (the first landlord) and yourself (the second landlord), they might challenge you on anti-avoidance grounds (e.g., the ‘Ramsay Principle’). In UK tax law, the Ramsay Principle broadly states that if a transaction has pre-arranged artificial steps, the only purpose of which is to avoid paying tax, the effect of the transaction as a whole should be taxed. 

My daughter owns outright and rents out a house. She is in the higher tax bracket. Can she let it to me at low rent, and can I then sub-let it at market rent, thus moving the income into the lower tax bracket? 

Arthur

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This question was first printed in Tax Insider in May 2025.