SPV’s & SPV MORTGAGES
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- SPV’s & SPV MORTGAGES
Use a limited company (SPV) to purchase investment properties
Benefits Summary
🔸 More tax-efficient than owning property in your own name.
🔸 Protect your personal money if something goes wrong.
🔸 Easier to qualify for finance or mortgage SPV for property purchases.
🔸 More suited to property investors looking to grow their portfolio.
🔸 Very tax-efficient for extracting profits from property purchases and sales through an SPV property company.
🔸 It can be used as a succession tax planning tool to pass assets to children.
What is an SPV?
- An SPV (Special Purpose Vehicle) is simply a private limited company set up only to buy and rent out property — often referred to as a special purpose vehicle buy-to-let company.
- The property belongs to the company, not to an individual.
- This separation helps protect your personal assets and makes it easier to qualify for an SPV buy-to-let mortgage.
SPV Requirements
- Minimum of 1 Shareholder and Director.
- Director Requirements
- At least 1 director needs to be a Resident in Ireland.
- Working and paying tax in Ireland.
Unlimited number of shareholders from all nationalities can own an SPV for property investment.
How to Set up an SPV
A Qualified Accountant will be required to set up an SPV.
A Company name must be chosen and registered.
A Company bank account must be open.
Company Shareholders Names should be declared.
Taxation Benefits of SPVs
Taxation on profits - Corporation tax.
- 25% on non-trading income Profits (e.g, Rental Income).
Director Loans into the company to fund deposit for house purchase.
Director benefits
- Can be extracted tax free from SPV and paid back to director.
- Interest can also be charged on Director loans.
The SPV
- Loan repayments are tax-deductible.
- Interest repayments are tax-deductible.
These SPV tax benefits make an SPV limited company buy-to-let mortgage highly efficient for investors.
Reducing Corporation Tax on Profits
Tax deductible expenses that reduce Corporation Tax
- 1. Pension contributions are permitted through revenue rules within an SPV
- 2. Family members can be hired and paid a salary from the business
- 3. Subsistence/Mileage can be paid from the company
- 4. Director loan repayments and interest
- 5. Salaries of family members (up to €13k per annum very tax efficient per member)
Capital Acquisition Tax Planning using SPV’s
SPVs can be used as a method of passing assets onto family members and reduce/eliminate Capital acquisition tax liabilities (gift or inheritances).
Examples:
- Making children 100% shareholders of the SPV and you as the director with no shareholding.
- Gifting €3000 worth of shares of SPV to your children each year until they own 100% of shareholding.
The following documentation must be provided for your SPV application.
Company Name Details
- Your chosen company name (must be unique and approved by CRO).
Company Registered Office Address
- An official Irish address where CRO correspondence will be sent.
- Anti Money Laundering Documentation for all Directors and shareholders.
- Recent utility bill or bank Statement of the Company (usually within the last 3 months).
SPV Mortgages
- Shareholders/directors of an SPV can apply for a mortgage through an SPV.
- It is the SPV who is borrowing the money, not the individual.
Conditions of an SPV Mortgage
Directors’ Requirements
- Minimum Salary of €40,000 (can be from combined director salaries).
- Between the ages of 21 and 70.
Max Mortgage
- 70% of the Property market value.
Deposit Required
- 30% of property purchase price (directors Loans/or loans from Subsidiary companies etc).
Term
- 5–35 year period.
- Will Lend to youngest Shareholders/ directors 80th birthday.
Interest Rate
- Variable rate - 4.80% to 5.80%.
- 10 year interest Only option (rolling onto capital & interest afterwards).
- Capital and Interest option.
Affordability based on Property investment only
- Rent must equal 1.2 times mortgage repayments.
- 85% when director has more than 1 Residential properties.
- Individual Income not assessed so easier to qualify.
Overpayment option
- No penalty to or limit to overpaying mortgage.
Simplified Application process
- Individuals income and personal finances not assessed so a significant amount of paperwork is not required.
Buy-to-Let Mortgage vs. SPV Mortgage
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Aspect
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SPV Ownership
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Personal BTL Ownership
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Ownership
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Property is owned by a limited company (SPV)
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Property is owned personally by the individual
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Establishment
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Company
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Individual
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Maximum Mortgage
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70% of Property Value
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70% of Property Value
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Minimum Deposit
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30% of Property Value
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30% of Property Value
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Transfer to Children
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Shares in the company can be passed on
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Property itself is inherited
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Buy-to-Let Mortgage vs. SPV Mortgage
Tax efficient (income & gains)
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Aspect
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SPV Ownership
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Personal BTL Ownership
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|---|---|---|
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Income Tax on rental income
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25% corporate tax on non trading income and 12.5% tax on trading income.
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If rental income is above 14k, whole income is exposed to 50% tax. |
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Mortgage interest
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Deductible as business expense for SPV.
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Deductible from rental income for BTL.
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Pension contributions
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Can contribute rental profits to pension (agebased limits apply).
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Cannot use rental income for pension.
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Deposit extraction
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Directors can show deposits as laon to the company, and withdraw them tax free, when profits are available, reducing tax liability. |
Deposits cannot be withdrawn unless property is sold out. |
Pre Submission Documents required to apply for an SPV mortgage
ANTI MONEY LAUNDERING DOCUMENTATION
- Proof of ID
- Proof of address
- Proof of PPS number
Proof of income
Self Employer/Directors
- 2 Years Certified Accounts ( Financial Statement audited by your Accountant)
- 2 Years Form 11s & Chapter 4s(Proof Of Income)
- Tax Clearance Certificate ( Letter From Accountant Confirming Tax affairs are up to date)
- Minimum 6 months Loan statements held by the company
Employees
- Last 3 Payslips
- Last 2 years (EDS’s) Employment details summary (formerly known as p60)
- Signed Salary Cert from your employer
AN UP TO DATE CREDIT REPORT (CCR) IS REQUIRED FOR ALL SHAREHOLDERS AND DIRECTORS
Other Documents that may be Required
- Tenancy documents - if you are refinancing an investment property;
- Foreign Credit Checks – If you have lived in a different country in the last 5 years;
- Additional Loan Statements - If you are aware of any debts, that do not appear on the Central Credit Register report, 24 months statements required.
SPV Documents Required – Post AIP
The following are required at a later stage – post mortgage AIP
SPV company related documents
- Certified copy of certificate of incorporation.
- Certified copy of Memorandum of Articles of Association or Constitution.
- Copy of a recent SPV bank statement (only if existing SPV).
- These documents will be provided by your accountant once an SPV is set up.
Mortgage Process:
1) Submit pre-submission documents mentioned above.
2) Pre-submission Meeting:
- Review all documents
- Create a cover letter
- Submit to the provider
3) Post submission meeting:
- Review AIP condition
- Order valuation
- Engage with Solicitor
- Set up SPV with Accountant
- Apply for Mortgage Protection
- Find a property and put down a deposit, and send confirmation of address to us
4) Sign the Loan offer, transfer.
5) 30% deposit into SPV bank account.
6) Apply for house insurance and put in place.
7) Draw down your funds.
FREQUENTLY ASKED QUESTIONS (FAQ's)
A clear, factual FAQ sheet for clients considering buy-to-let property through a Limited Company (SPV), a subsidiary SPV, or personal ownership. This is general information and should be confirmed for your specific circumstances.
Q1. What is the close company surcharge, and are there ways to mitigate it?
Ans: A close company can face a 20% surcharge on undistributed after-tax estate/investment income (including rental income) if it is not distributed within 18 months of the end of the accounting period.
There are many tax deductible expenses that can reduce the profits of The business. Below is a list of some commonly used expenses
- Director salaries
- Employing family members
- Pension contributions
- Using funds as a deposit to purchase additional properties
- Repaying director or intercompany loans
- Mortgage interest relief
- Depreciation
- Accountancy fees
- Maintenance costs
Q2. What tax-deductible expenses can be used to reduce corporate tax?
Ans: Generally, rental profits are taxed on the net amount after allowable expenses. Typical allowable costs can include insurance, repairs and maintenance, management /accountancy fees, certain service charges paid by the landlord, and qualifying mortgage interest (subject to Revenue conditions). Capital improvements are not normally deductible as a revenue expense, and Local Property Tax (LPT) is not deductible.
Q3. How can estate planning tools, like gifting €3K per parent, be utilised?
Ans: The Small Gift Exemption allows €3,000 per disponer (giver) per recipient per calendar year to be given without using the recipient’s CAT threshold. In practice, where two parents each gift €3,000 to a child, that can allow €6,000 per child per year (subject to proper structuring). With companies, gifting shares can be used as part of succession planning, but CAT rules and the nature of the company’s activity must be considered.
Another point to note is that children/individuals who are shareholder of SPVs and subsequently purchased investment properties keep their first time buyer status. This means that they can still qualify for the help to buy scheme, first home scheme etc.
Q4. What are the tax implications of selling a property?
Ans: If owned personally, a gain may be subject to Capital Gains Tax (CGT) at 33% (subject to reliefs/exemptions). If owned by a company, the gain is within corporation tax on chargeable gains (effectively aligned to the 33% CGT rate). Where a company sells the property, further tax may arise when you extract proceeds personally (for example via dividends or salary), so exit planning is key.
Q5. How are directors ' loans and intra-company loans taxed, and how do they compare to an individual' s funding for a property deposit?
Ans: A director loan is money you lend to the company. Repayment of the loan principal is generally a return of capital (not income) and is not tax-deductible for the company because it is not an expense. This can be useful because it may allow you to extract the original deposit tax free over time (if the company has cash). If the company pays interest, the rules can be complex for close companies (including circumstances where interest may be treated as a distribution). Intracompany loans (parent to subsidiary) are similar in principle but should be structured commercially and documented properly.
Q6. How do I set up an SPC/SPV (Special Purpose Company)?
Ans:
(1) incorporate an Irish LTD company,
(2) adopt a constitution and appoint directors/secretary,
(3) open a business bank account,
(4) register for taxes as needed,
(5) file beneficial ownership details to the RBO, and
(6) maintain proper books/records and compliance (CRO filings and tax returns).
Q7. What are the filing obligations for returns??
Ans: Companies usually have ongoing obligations including: CRO annual return filing (with financial statements where required), maintaining and filing beneficial ownership details (RBO), and filing corporation tax returns (CT1) and paying corporation tax by the relevant deadlines. Your accountant will typically manage the filings, but directors remain responsible for compliance.
Q8. Can I borrow for both residential and commercial property purchases?
Ans: Potentially, yes — but lender policy, underwriting, and security requirements differ materially between residential buy-to-let, commercial property, and company borrowers. Tax treatment also differs (for example, residential lettings are generally VAT-exempt). It’s important to match the structure to the asset type and lender appetite.
Q9. Can I purchase a property using my existing trading company?
Ans: It can be possible, but it is a strategic decision. Rental income in a company is generally treated as non-trading income taxed at 25%, and close company surcharge issues may arise if profits are retained. Many investors choose a separate SPV or subsidiary SPV to ring-fence risk and keep trading and investment activities clearly separated.
Q10. What does SPV mean in mortgages?
Ans: An SPV mortgage is a special-purpose vehicle mortgage used by a limited company SPV to buy and manage investment properties. It lets investors hold property in a company name instead of personally.
Q11. What is an SPV mortgage?
Ans: A buy-to-let SPV mortgage allows a special-purpose vehicle company to purchase rental properties. The loan is in the company’s name, and repayments come from rental income.
Q12. What is the purpose of an SPV?
Ans: An SPV (Special Purpose Vehicle) is set up to own and manage property separately from personal finances, helping investors limit risk and manage SPV tax benefits.
Q13. What are the benefits of an SPV company?
Ans: An SPV property company protects personal assets, offers potential tax advantages, and makes it easier to grow a buy-to-let SPV portfolio.
Q14. What is an example of an SPV?
Ans: An SPV for property investment is a company created to buy and rent out homes under a limited company SPV mortgage.
Q15. Who typically uses SPVs?
Ans: SPV property companies are mainly used by landlords and investors building or refinancing buy-to-let SPV mortgages.
Q16. How many investors can be in an SPV?
Ans: An SPV for property purchase can have one or several shareholders, depending on the company setup.
Important notice: This FAQ sheet is for information purposes only and does not constitute tax, legal, or investment advice. Tax rules and lender criteria can change. Always obtain personalised advice based on your circumstances.
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