Writing in Propert118, Mark Alexander warns of the danger of Section 24 being extended to Ltd Companies.

Warning that Section 24 still casts a long shadow nearly a decade after its introduction. For many landlords, it was the moment trust was broken: the sudden withdrawal of mortgage interest relief for individuals changed investment psychology permanently.

Today, whenever a Budget approaches, the same question returns:

Will they extend Section 24 to limited companies?

A fear rooted in experience

The anxiety is understandable. Section 24 arrived abruptly, without consultation, and in a political climate where landlords were blamed for crowding out first-time buyers. The measure was technically simple, politically convenient, and popular with the public narrative of the time.

The trauma of 2015 has left many landlords perpetually braced for the next shock.

But Section 24 never applied to companies

Section 24 sits entirely within personal income tax law (ITTOIA 2005).
Companies, by contrast, operate under the Corporation Tax Act 2009 — a completely separate legislative system.

Companies were not given a “loophole”; they simply fell under a different tax regime.

Political intervention vs structural reform

The fear persists because landlords worry that if government broke a long-standing principle once, it could do so again. But extending Section 24 into the corporate tax system would not be a small amendment — it would represent a fundamental restructuring of corporation tax.

Such a move would trigger:

• Pushback from housing associations

• Objection from institutional investors

• Disruption to pension funds

• Resistance from REITs and large-scale build-to-rent operators

The Treasury would be engaging not just with private landlords but with major regulated institutions — a political and economic battle far larger than that of 2015.

The correct approach: measured assessment, not panic

The concern is not irrational, but it must be separated into:

• Psychological fear, shaped by the memory of 2015, and

• Structural reality, which shows significant barriers to extending Section 24 to companies.

This issue deserves — and is now receiving — a clearer, evidence-based evaluation rather than emotional reassurance.