Property118 is a champion for landlords, offering essential solutions that help them move their property businesses into a company without being hit by large, unnecessary costs. One of the biggest challenges landlords face during this process is dealing with expensive financing. Property118 has created legal strategies that allow landlords to delay these major costs, making the transition much easier and more affordable.

But now, HMRC is unfairly targeting these helpful solutions, accusing Property118 of promoting tax avoidance. Despite these claims, Property118’s strategies follow clear legal rules and are designed to solve real business problems, not avoid taxes.

Property118 is fighting back, using strong legal arguments and case law to show that their solutions are both lawful and necessary. While HMRC’s actions could force landlords into costly financial situations just to restructure their businesses, Property118 is standing up to protect them

We need your support to stand up against HMRC's unjust actions.

BACKGROUND

In February 2024, HMRC issued Scheme Reference Numbers (SRNs) to Property118 and its clients under the Disclosure of Tax Avoidance Schemes (DOTAS) legislation. Industry professionals have likened this to placing a "KICK ME" sign on the backs of these businesses and their owners.

Property118 swiftly appealed HMRC’s decision to the Tax Tribunal on 5th March 2024, arguing that the recommendations made by Property118 did not provide any tax advantages beyond those intended by legislation and HMRC's extra statutory concessions established over 50 years ago. HMRC was copied into the full details of this appeal on the basis that this would give HMRC more time to reconsider its position and to avoid delays due to the Tribunal having a two-month backlog of work.

On 10th May 2024, the Tax Tribunal finally gave HMRC 60 days to make a “Statement of Case” to justify their actions. One would expect HMRC to respond promptly, especially given that Property118 informed them of the appeal shortly after it was submitted. If HMRC truly believed they had good reason for issuing the SRNs, why did they subsequently apply to the Tax Tribunal Judge to delay the presentation of their case?

Worse still, HMRC wanted to split our Appeal into two separate cases (even though the arguments are largely similar) and double the legal costs for our appeal.

By the deadline of 9th July 2024, HMRC would have had almost five months to justify its actions. Instead, their solicitors have used delay and procedural tactics that drain Property118’s resources, preventing us from assisting other landlords and incurring additional legal costs, further depleting our financial reserves to dangerously low levels. The outcome of this is that as of 1st July 2024 the Tax Tribunal Judge issued new directions granting HMRC a further 60 days to submit their Statement of Case.

In summary, HMRC has got its way and managed to ‘kick the can down the road’ yet again. Assuming they don’t manage to delay the justice process even further it will have been well over six months by the time they provide proper justification for their actions. This is badly impacting our ability to trade to remain in business. This is because we (and all other professional advisers) cannot, with a clear conscience, assist any other landlords to incorporate as a result of the uncertainties created by HMRC’s actions.

HOW YOU CAN HELP

We are raising funds to ensure Property118 has the necessary resources to see this legal battle through to the end. Justice can only prevail if we have the funds to continue fighting against HMRC's unfair litigation practices.

Your support will help us to:

- Cover ongoing legal expenses

- Sustain our operations and support services for landlords

- Challenge HMRC's unjust actions and seek a fair outcome

Join us in this critical fight for fairness. Every contribution makes a difference and brings us one step closer to justice.

Thank you for your support.

From Underdog to Champion

We did it once. We can do it again.

The Property118 Action Group made history when we successfully challenged the West Bromwich Mortgage Company, securing millions in overpayments for landlords across the UK. Our victory was a landmark achievement for the property industry.

We’ve encountered both overwhelming gratitude and unexpected criticism. Some have questioned our motives, even those we helped previously. It’s a stark reminder that while we strive to do right by everyone, it’s impossible to please all.

Your support is crucial as we continue to fight for fair treatment and protect the rights of landlords. By donating, you’re not just helping us; you’re investing in a stronger, fairer property industry.

Proof of our success:

BBC

The Times

Daily Mail

The Telegraph

UPDATE - 11th September 2024

Last week, HMRC Complaints were asked to consider that representations relating to Discovery Assessments were 115 days past the 30-day service standards. We have since been advised that they are experiencing a high volume of work and the complaint will be considered within 16 weeks “unless they cannot” !!!

UPDATE - 6th November 2025

We understand that the Chartered Institute of Taxation met with HMRC yesterday, with transfers of beneficial interest and Extra-Statutory Concession D32 (ESC D32) on their agenda. Although it may be a month or two before the minutes of that meeting are published, this discussion provides useful context for our ongoing case.

In parallel, we have been working closely with counsel over the past several weeks to prepare a robust set of representations, which we submitted to HMRC yesterday. This comprehensive 51-page document, crafted through extensive collaboration, offers a well-supported legal argument and accompanying evidence, presenting our position on why we believe the First-tier Tribunal (FTT) would uphold our case if it progresses to that stage. This submission also fulfils HMRC’s condition for their ‘in-principle’ agreement to a meeting with us.

HMRC responded promptly, advising us that our representations have been circulated among all relevant stakeholders (decision makers), who will need time to review the detailed document. Given the extent of the submission, this request for additional time is entirely reasonable.

In light of this development, counsel has recommended that we pause the FTT process while awaiting HMRC’s response and any potential meeting. This approach aligns with our preference to resolve the matter collaboratively without resorting to a tribunal hearing, which would take significantly longer. Should the dispute proceed, this pause will allow us to refine our evidential approach, focusing on precise, relevant documentation if required. We are mindful that the FTT prefers concise, targeted evidence over exhaustive submissions, and we are keen to respect that preference.