Do SIS arrangements breach mortgage terms and invalidate Section 162 relief?
20th August 2026
A criticism repeated against Substantial Incorporation Structure (SIS) arrangements is that transferring the beneficial ownership of mortgaged properties to a company must have breached the mortgage terms, making the transfer ineffective and automatically invalidating Section 162 Incorporation Relief. That argument compresses several separate legal questions into one convenient conclusion. The evidence heard during the ten-day […]