An SPV or trust mortgage is a residential mortgage where the property is owned by a company, trust or other non-natural person rather than the borrower personally. The structure is most often used by non-doms, foreign nationals, families planning inheritance ahead of time, and HNW individuals who want their primary or second residence held outside their personal balance sheet. The lender list narrows considerably, the SDLT and ATED treatment changes materially, and pricing carries a small premium. The mortgage is still achievable, it just has to be placed at a desk that engages with the structure.
This guide is what we have found over the last few years working with SPV and trust ownership cases at HNW level. It covers what SPV and trust mortgages actually are, who uses each structure and why, how SDLT and ATED apply, which lenders engage at private bank and specialist level, what changes versus personal name ownership, and how to put the application together so the structure does not slow it down.
Fox Davidson arranges large mortgages for UK and international HNW clients from £250,000 upwards, including SPV ownership, bare trust, discretionary trust and offshore structures. Most of these cases sit at private banks. A small number of building society HNW desks and specialist HNW lenders also engage where the structure is straightforward and the documentation is clean.
The basics
What is an SPV or trust mortgage?
An SPV (Special Purpose Vehicle) mortgage is a residential mortgage where the property title is held by a UK or offshore limited company set up specifically to own the property. A trust mortgage is the equivalent where the property is held by trustees under a trust deed for the benefit of named or class beneficiaries. The borrower behind both structures is usually a private individual or family. The structure sits between them and the property.
The reasons for using a structure rather than buying in personal name fall into a few clear groups. Privacy: the title at the Land Registry shows the company or trust name, not the individual. Inheritance tax planning: assets held outside the personal estate can be removed from IHT exposure depending on the structure and the time held. Foreign national or non-dom ownership: a UK or offshore SPV can simplify the position for non-residents and may interact more cleanly with the borrower’s home tax regime. Family asset protection: a discretionary trust allows trustees to direct benefit to family members across generations.
The mortgage product is still a regulated residential mortgage where the borrower or a connected person will occupy the property. The lender treats the company or trust as the legal borrower, but underwrites the case against the wealth and income position of the individual standing behind it. This is the key practical point: it is not a buy-to-let or commercial product, even though the ownership is corporate.
Who uses these structures
Who uses SPV or trust ownership for residential property?
Four borrower profiles account for most of the SPV and trust residential cases we place.
Every one of these structures has a tax and legal dimension that sits well outside what we as mortgage brokers advise on. The structuring decision is between the borrower, their tax adviser and their solicitor. Our role is to find the lender who will mortgage the structure once it has been chosen. We work alongside the borrower’s adviser team rather than instead of them.
SPV vs personal name
SPV vs personal name purchase: what are the trade-offs?
The decision to buy through a structure rather than in personal name is rarely about the mortgage alone. The mortgage costs more, the SDLT is higher, and there is an ongoing annual tax. The reasons to use a structure have to outweigh those three things for the case to make sense.
SDLT figures indicative for England, 2026 rates. Wales and Scotland have separate regimes. Always confirm with the borrower’s tax adviser.
The SDLT delta between SPV and personal name has narrowed since the 2nd home surcharge was increased. On a £4m London purchase as a second home in personal name, the SDLT comes in around £583,750. The same purchase through an SPV is taxed at the 15% non-natural person flat rate, around £600,000. The gap is around £16,250 on this example, smaller than commonly assumed. On larger purchases the gap widens; on smaller purchases it can reverse.
The ongoing ATED charge is the more material cost. A £4m property held by a company faces an ATED charge of around £18,000 to £29,000 per year, depending on band. That is the cost most clients underestimate when first looking at SPV ownership.
SDLT and ATED
How do SDLT and ATED apply to SPV residential purchases?
Two tax features make SPV ownership of UK residential property materially different from personal name ownership.
The SDLT 15% non-natural person rate. Where a UK company, partnership with a corporate partner, or collective investment scheme buys a residential property worth £500,000 or more, the SDLT is charged at a flat 15% rate. This is the “non-natural person” rate. It replaces the standard progressive bands. There are exemptions where the property is acquired for a qualifying business purpose (commercial letting, property development, trade), but those exemptions do not apply where the property is occupied by the individual behind the SPV or by a connected family member.
The Annual Tax on Enveloped Dwellings (ATED). Properties worth £500,000 or more owned by a non-natural person face an annual ATED charge regardless of whether the property is occupied or vacant. The charge increases with the property’s value band and is uprated each tax year.
The two charges together change the economics meaningfully. On a £4m property held in an SPV, the up-front SDLT is around £600,000 (versus around £583,750 in personal name as a second home), and the annual ATED is around £18,000 to £29,000 per year. Over a ten year hold, the ATED alone adds £180,000 to £290,000 of cost.
Reliefs from ATED exist where the property is genuinely let to unconnected tenants, used for a qualifying property trade, or held by a property development company. None of those reliefs apply where the property is the residence of the individual standing behind the SPV. The full charge applies.
Trust structures
How do trust structures work for HNW mortgages?
Trusts work differently from SPVs. The trust does not have separate legal personality in the same way a company does. The trustees hold legal title to the property on behalf of the beneficiaries. Lender treatment depends on which type of trust is used.
Bare trust
The simplest trust structure. The trustees hold legal title for a single beneficiary who is absolutely entitled to the property. The most common use is a parent buying for an adult child, or a couple holding for a minor child until the child reaches majority. For mortgage purposes most lenders treat a bare trust as economically equivalent to direct ownership by the beneficiary. SDLT and ATED treatment usually follows the beneficiary’s tax position rather than the trustees’. The lender list is reasonably broad: most building society HNW desks and several specialist HNW lenders engage. Private banks also engage. The friction is low.
Discretionary trust
More complex. The trustees hold legal title and have discretion over how to apply the property’s benefit among a class of beneficiaries. The trust is treated as the owner for SDLT and IHT purposes. The lender list narrows materially. A small number of private banks and specialist trust lenders engage. Building society HNW desks rarely engage with discretionary trusts. The trustees need to be the borrower; trustee credit and asset position is reviewed alongside the settlor’s wider financial picture. The case usually completes in 10 to 14 weeks because of the trustee documentation and the legal review of the trust deed.
Offshore trust
The narrowest lender list. Offshore trusts (Jersey, Guernsey, Isle of Man, BVI, Cayman) holding UK residential property are typically only mortgaged by private banks with active offshore desks. The case requires the trust deed, trustee KYC, source of wealth documentation, and (often) confirmation from the trustees’ legal counsel on the trust’s powers to borrow and grant security. SDLT and ATED apply at the non-natural person and full ATED rates. Completion timelines run 10 to 16 weeks. This is the deepest end of the structuring market and we work it alongside the borrower’s offshore trust lawyers and tax advisers throughout.
Lender access
Which lenders offer SPV and trust residential mortgages?
The active market for SPV and trust residential lending in 2026 splits into three bands. The width of the panel depends heavily on the structure.
| Lender band | SPV | Bare trust | Discretionary trust | Offshore trust |
|---|---|---|---|---|
| Private banks (Coutts, Weatherbys, Arbuthnot Latham, Investec, Hampden & Co, Lombard Odier) |
Yes, most active | Yes | Selected desks | Selected desks with offshore capability |
| Building society HNW desks (Skipton, Newcastle, Cumberland, Saffron, Cambridge) |
Rarely | Yes | Rarely | No |
| Specialist HNW lenders | Yes, narrower panel | Yes | Selected lenders | Rarely |
Private banks are the dominant route for SPV residential and for discretionary or offshore trust structures. At HNW level, private bank engagement is usually conditional on an existing or transferred AUM relationship, although a small number of private banks will engage on a dry-lending basis (no AUM) for the right profile. Our dry lending guide covers that path in detail.
Specialist HNW lenders engage with SPV and bare trust structures at lower loan sizes (from £500k to £3m). Building society HNW desks are the cheapest pricing but the narrowest engagement: bare trusts only, and on a small loan size basis. Discretionary and offshore trusts almost always need a private bank.
Why the structure conversation needs to happen first
The structure decision is made by the borrower’s tax adviser and solicitor, not the broker. But the structure determines the lender list. We have seen cases where a discretionary trust was set up to hold the property, the SDLT was paid, the legal title was put in place, and only then did the borrower come to us to arrange the mortgage. At that point the lender list is what it is. If no engagement is available, the structure has to be unwound, which is expensive and slow.
The simple rule we apply: speak to a specialist mortgage broker before the structure is locked in. We do not advise on the structure choice, but we will confirm which lenders engage with each option before the legal work starts. That five-minute conversation saves a lot of expensive rework.
Worked example
£4m London purchase via SPV: how the costs stack up
A representative case, anonymised. Client is a Hong Kong-based UK national returning to the UK in 18 months. Buying a £4m London property as the family’s primary residence on return. The borrower’s tax adviser has recommended purchase via a UK SPV for reasons connected to the borrower’s UK tax position on return. £1m deposit available, £3m mortgage needed. Property to be let on short market rent for the 18 months before the family moves in.
Year 1 costs (purchase year)
Ongoing annual cost (years 2+)
The deal completed within twelve weeks of instruction. The private bank engaged on the SPV ownership without requiring AUM transfer (a dry-lending arrangement), against the borrower’s £6m offshore investment portfolio standing as supporting wealth evidence. Pricing on the 5-year fixed came in at 5.5% interest-only, 0.4 percentage points above the equivalent personal-name HNW mortgage at the same private bank. The borrower accepted the premium because the SPV structure was driven by tax planning that materially outweighed the interest cost over the planning horizon.
One detail worth flagging: the property is let on short market rent for the 18-month period before the family moves in. The lender treated this as a transitional arrangement rather than a buy-to-let case, on the basis that the SPV’s longer-term purpose was to hold the family’s primary residence. This treatment is at the underwriter’s discretion and not universally accepted. We had the conversation with the relationship manager and underwriter before the formal application.
Rates
What rates apply to SPV and trust mortgages in 2026?
Pricing for SPV and trust residential mortgages sits 0.3 to 0.6 percentage points above the equivalent personal-name HNW mortgage at the same lender. The premium reflects the additional legal work, the narrower secondary market for the loan, and the structure-specific underwriting required.
Standard 5-year fixed rates at 70% to 75% LTV for SPV residential through private banks currently run in the 5.1% to 5.8% band. Bare trust pricing is closer to standard HNW rates because most lenders treat the bare trust as economically equivalent to direct ownership. Discretionary and offshore trust pricing carries the full premium and runs at the upper end of the band, sometimes 0.7 percentage points above personal-name equivalent.
Private bank pricing varies meaningfully based on AUM relationship. At significant AUM (typically £3m or more for SPV residential), the structure premium can be partly absorbed by relationship pricing. On a dry-lending basis the premium is typically applied in full.
Documentation
What documentation do lenders need?
The documentation pack for SPV and trust residential lending is more involved than personal-name HNW mortgages. The full pack typically includes:
- For SPV ownership: certificate of incorporation, memorandum and articles of association, register of members and directors, shareholder structure chart, last set of company accounts (where the SPV is not newly formed), and source of funds for the company’s share capital and any director’s loan.
- For bare trust: trust deed, trustee identification (full KYC), beneficiary identification, and confirmation of the beneficial ownership position from the borrower’s tax adviser where helpful.
- For discretionary or offshore trust: trust deed and any supplemental deeds, full trustee KYC, settlor source of wealth evidence, beneficiary class detail, trustee legal opinion on power to borrow and grant security (often required), and offshore tax confirmation where applicable.
- For all structures: personal documentation for the individual standing behind the structure (statement of net worth, three months of investment portfolio statements, last two years of tax returns, bank statements, property valuations of other holdings) on the same basis as a personal-name HNW application.
- Source of wealth evidence: particularly important where the structure is offshore or where significant funds have moved into the SPV or trust recently. The lender’s compliance team will want a clear documented trail.
The structure documentation is what separates SPV and trust cases from straightforward HNW personal-name cases on timeline. Where the trust deed and trustee KYC are ready on day one, completion can compress materially. Where they have to be built or gathered during the application, timelines extend.
Pitfalls
Common reasons SPV and trust mortgage applications fall over
Three patterns account for most of the failed cases we see arrive at our desk after declines elsewhere.
Structure locked in before lender engagement confirmed. Most common single problem. The SPV is incorporated or the trust deed executed and the SDLT paid, then the borrower comes to us. The lender list for the structure as set up turns out to be too narrow or unavailable. The fix is expensive: either unwind the structure and use a different vehicle, or accept whatever lender will engage, often at unfavourable pricing.
Direct application to a high street lender. The borrower or their solicitor submits the mortgage application directly to a high street lender that does not engage with the structure at all. The decline lands quickly, a hard credit search is logged, and the case arrives at the right desk with that decline on file. Manageable but avoidable.
Incomplete trustee documentation. The trust deed is on file but the trustees have not been formally KYC’d at the lender’s standard, the trust’s borrowing power is not confirmed in writing, or the trustees’ legal counsel has not been instructed to issue the standard opinion the lender requires. The case stalls until the documentation catches up. This is the cause of most three-month-plus completion timelines in this market.
Our process
How we approach SPV and trust mortgage cases
The standard process we run for an SPV or trust mortgage client starts well before the structure is locked in. The first conversation is usually a 20-minute call with the borrower (often alongside their tax adviser or solicitor) to understand the planned structure, the property, the loan size needed and the borrower’s wider wealth position. We confirm which lenders engage with the planned structure before any legal work starts.
Once the structure is in place and the documentation pack is ready, we soft-model against the four to six lenders most likely to engage at sensible terms, then submit to the chosen lender for an indication. Hard application follows once the indication is positive. Most SPV and trust residential cases complete in eight to twelve weeks, with offshore trust cases running ten to sixteen weeks.
The conversation we always start with: which lender’s structuring criteria fit the borrower’s chosen vehicle without compromise? The structure decision is the borrower’s; the lender selection is ours. Get the sequence right and the case runs smoothly. Get it wrong and the structure has to bend to fit whatever lender will engage.
FAQ
Frequently asked questions
Can I get a residential mortgage through a UK limited company?
Yes, through a narrow lender list. Most high street lenders do not engage with SPV residential. Private banks are the dominant route. A small number of specialist HNW lenders also engage. The mortgage product is a regulated residential mortgage where the borrower or a connected person will occupy. The structure is most common among foreign nationals, non-doms, and HNW families using SPVs for tax or privacy reasons.
What is the SDLT rate on SPV residential purchases?
A flat 15% rate applies to UK residential properties worth £500,000 or more bought by a UK or offshore company, partnership with a corporate partner, or collective investment scheme where the property will not be used for a qualifying business purpose. The 15% rate replaces the standard progressive bands. On a £4m residential purchase the SDLT is £600,000. The borrower’s tax adviser will confirm the rate that applies to a specific case.
What is ATED and when does it apply?
ATED stands for Annual Tax on Enveloped Dwellings. It is an annual tax charged on UK residential property worth £500,000 or more held by a non-natural person (a company, partnership with a corporate partner, or collective investment scheme). The charge applies regardless of occupation and is uprated each tax year. 2025/26 bands ran from £4,400 per year for £500,000 to £1m properties up to £287,500 per year for properties worth more than £20m. Reliefs are available for property let to unconnected tenants, used in a qualifying property trade, or held by a property development company.
How does a bare trust mortgage work?
A bare trust is the simplest trust structure. The trustees hold legal title for a single beneficiary who is absolutely entitled to the property. Most lenders treat a bare trust as economically equivalent to direct ownership by the beneficiary for mortgage purposes. SDLT and ATED treatment usually follow the beneficiary’s tax position rather than the trustees’. The lender list is reasonably broad: building society HNW desks, specialist HNW lenders, and private banks all engage.
Can I get a residential mortgage on a property held in a discretionary trust?
Yes, but the lender list is narrow. A small number of private banks and selected specialist trust lenders engage with discretionary trusts holding UK residential property. The trustees are the legal borrower; trustee credit and asset position is reviewed alongside the settlor’s wider financial picture. The trust deed has to be reviewed by the lender’s legal team and the trustees’ borrowing powers confirmed. Completion typically runs 10 to 14 weeks because of the additional legal review.
Can offshore trusts borrow against UK residential property?
Yes, in selected cases. Offshore trusts based in Jersey, Guernsey, Isle of Man, BVI or Cayman holding UK residential property are typically only mortgaged by private banks with active offshore desks. The case requires the trust deed, full trustee KYC, source of wealth documentation, and confirmation from the trustees’ legal counsel on the trust’s power to borrow and grant security. SDLT applies at the 15% non-natural person rate. ATED applies. Completion timelines run 10 to 16 weeks.
How much can I borrow on an SPV residential mortgage?
Maximum LTV on SPV residential at private banks is typically 70% to 75%. Specialist HNW lenders engage to similar LTV levels. Loan sizes range from £1m to £50m+. Borrower wealth is assessed on the same basis as a personal-name HNW mortgage: net asset position, cash flow available for monthly servicing, and a credible repayment plan for the loan term. The SPV is the legal borrower but the underwriting is on the individual behind it.
What rates apply to SPV and trust mortgages?
SPV and trust residential pricing typically sits 0.3 to 0.6 percentage points above the equivalent personal-name HNW mortgage at the same lender. Bare trust pricing is closer to standard HNW rates because most lenders treat the bare trust as direct ownership. Discretionary and offshore trust pricing runs at the upper end of the premium band, sometimes 0.7 percentage points above. 5-year fixed rates at 75% LTV currently run in the 5.1% to 5.8% range across the SPV and trust market in 2026.
Do I need to move investments to the private bank to get an SPV mortgage?
Often, but not always. Private banks typically prefer an AUM relationship to support an SPV or trust residential mortgage, and pricing is usually meaningfully better with AUM in place. A small number of private banks engage on a dry-lending basis (no AUM transfer) for the right profile, accepting a pricing premium and confirming wealth via external statements. Building society HNW desks and specialist HNW lenders do not require AUM at all but engage with a narrower set of structures.
Should I set up the structure before or after talking to a mortgage broker?
Before. Speak to a specialist mortgage broker at the structure planning stage, alongside your tax adviser and solicitor. The structure decision is yours and your advisers’; the lender list is ours. A 20-minute conversation before the structure is locked in will confirm which lenders engage with the planned vehicle. The most expensive mistake we see is the structure being incorporated or the trust deed executed before the lender engagement is confirmed.
SPV and trust mortgages are placed before the structure is locked in.
The structure decision is between you, your tax adviser and your solicitor. The lender list is between you and us. When you call, we confirm which lenders engage with the planned structure before any legal work starts.