HMRC has reportedly sent ‘nudge’ letters to agents and taxpayers who have used ‘hybrid’ property tax planning as detailed in their Spotlight 63.

The news follows the tax body’s Spotlight 63 warning about hybrid partnerships. It said these schemes try to avoid tax by allowing individual or joint property landlords to transfer their properties to a limited liability partnership (LLP) with a corporate member.

HMRC’s Wealthy Team have launched a ‘one to many’ campaign, which involves sending one standard message to many customers.

What does the Spotlight 63 ‘nudge’ letter say?

The letter advises recipients to:

  • Withdraw from the scheme
  • Make a disclosure to HMRC by 31 January 2024
  • Settle their tax affairs

HMRC adds that failure to make a disclosure could lead to an enquiry.

The correspondence also includes a factsheet comparing HMRC’s view of the law to the advice the taxpayers may have been given when entering a scheme.

And it adds that anyone concerned about the schemes can also get independent tax advice or speak to a tax charity.

Our view

If you’ve received a ‘nudge’ letter from HMRC, you can talk to our team of independent tax advisers before responding to HMRC.

Call us on 07813 434195 or email

Steph Churchill

Stephanie Churchill

Managing director & co-owner of Churchill Taxation