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Making Tax Digital for Commercial Landlords: Key Rules and Exemptions

Making Tax Digital for Commercial Landlords: Key Rules and Exemptions

If you personally own commercial property, Making Tax Digital (MTD) for Income Tax may apply to you. While commercial landlords avoid the Section 24 mortgage interest restriction, they still need to navigate VAT, mixed-use properties, capital allowances and quarterly reporting requirements.

Raju GajurelRaju Gajurel
28 min read
Nov 19, 2025
Updated Jun 11, 2026

If you own shops, offices, warehouses, or other commercial property in your personal name, MTD applies to you. The good news: the rules are simpler than for residential landlords. No Section 24 restriction. Fewer quarterly categories. But the interaction with VAT, mixed-use properties, and capital allowances creates its own set of questions.

Most MTD guidance is written for residential buy-to-let landlords. If you own commercial property personally, a retail unit on a high street, an office above a shop, a small warehouse, a serviced office, or even a holiday cottage, you are left reading between the lines. 

Commercial property under MTD is, in many ways, simpler than residential. The Section 24 finance cost restriction that causes so much complexity for residential landlords does not apply. Your mortgage interest is fully deductible against profits, reported as a normal expense.  

But commercial landlords face their own set of questions: how does the option to tax for VAT interact with MTD? What happens with mixed-use properties? How do capital allowances work under quarterly reporting? And does MTD even apply if you own through a limited company? 

I will answer all of these. This article assumes you understand the basics and focuses on what is different, simpler, or more complicated for commercial landlords. If you are new to MTD entirely, start with our main guide: MTD for Income Tax (MTD ITSA).   

KEY TAKEAWAYS

  • MTD for Income Tax applies to individuals who own commercial property personally. Property held through a limited company is outside scope (a separate MTD for Corporation Tax regime has been signalled but not legislated). 

  • Commercial property finance costs are fully deductible. The Section 24 restriction is residential only, so your quarterly reporting has one fewer category. 

  • Mixed-use buildings (a shop with a flat above, for example) must be apportioned. The split affects every quarterly update and the year-end position. 

  • If you are VAT-registered or have opted to tax, your MTD ITSA quarterly updates use VAT-exclusive figures. The VAT element sits in your VAT return, not your income tax return. 

  • Capital allowances (SBA, plant and machinery, AIA) are not reported in quarterly updates. They are claimed in the Final Declaration. Track qualifying expenditure during the year so the year-end claim is ready. 

  • Since the FHL regime was abolished from 6 April 2025, holiday cottages and short-term lets are residential property income, not commercial. 

Does MTD Apply to Commercial Landlords? 

MTD ITSA applies if you personally own commercial property and your total qualifying income is above the relevant threshold. If you own your commercial property through a limited company, MTD for Income Tax does not apply to you yet. 

The qualifying income threshold and mandation timeline are exactly the same as for residential landlords. 

The first wave is already live: individuals with gross qualifying income of over £50,000 for the 2024/25 tax year are required to register for MTD from 6 April 2026. The threshold then falls to over £30,000 from 6 April 2027, based on 2025/26 income, and over £20,000 from 6 April 2028, based on 2026/27 income. 

HMRC does not look at your commercial rent in isolation. For MTD, qualifying income means your total gross income from property and self-employment before expenses. This includes commercial rents, residential rents and any sole trade turnover. 

For Example

A landlord with £20,000 of commercial rent and £35,000 of residential rent has a qualifying income of £55,000 and has been in scope since April 2026. Their first quarterly submission is on August 7th of the same year.

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If you own commercial property through a limited company, MTD for Income Tax does not apply to that income. But if you personally own a mix of residential and commercial property, all of it counts toward the qualifying income threshold and all of it must be reported through MTD once you are mandated. 

What Counts as Commercial Property? 

For MTD purposes, the distinction that matters is residential versus non-residential. Commercial property is any property that is not a dwelling. But the range of property types that fall under this umbrella is wider than most people realise. 

Property type 

Classification 

Notes 

Shops and retail units 

Non-residential 

High-street shops, kiosks, market stalls, retail parks 

Offices 

Non-residential 

Includes serviced offices and co-working spaces let to tenants 

Warehouses and industrial units 

Non-residential 

Includes storage facilities, light industrial, distribution centres 

Pubs, restaurants, cafés 

Non-residential 

The premises, not the trade. If you own the building and let it to an operator, it is a property business 

Hotels and guest houses 

Non-residential 

If operated personally with services, may be a trade rather than a property business 

Bed and breakfasts 

Mixed 

Often part residential (owner's accommodation) and part non-residential. See mixed-use section 

Serviced accommodation and holiday cottages 

Residential 

Since FHL abolition on 6 April 2025, treated as residential property income. Section 24 applies 

Garages and parking spaces 

Non-residential 

Whether standalone or let separately from a residential property 

Agricultural land and farm buildings 

Non-residential 

Including barn conversions let for storage or commercial use 

Mixed-use (e.g. shop with flat above) 

Mixed 

Must be apportioned. See mixed-use section 

Important

Since the abolition of the Furnished Holiday Lettings regime on 6 April 2025 (effected by Finance Act 2024), holiday cottages, Airbnb properties, and short-term furnished lets are treated as ordinary residential property income, not commercial. Section 24 now applies to their finance costs. If you previously treated holiday lets as a separate FHL business with fully deductible mortgage interest, that treatment ended on 5 April 2025. Your software and quarterly categorisation must reflect this change. 

How MTD Applies to Hotels, B&Bs, and Serviced Accommodation

This is where the classification gets important, because it determines which MTD rules apply to you. 

Hotels and Guest Houses Operated Personally

If you personally run a hotel or guest house, providing services such as cleaning, breakfast, reception, and linen changes, HMRC is likely to treat this as a trade (self-employment) rather than a property business. The property happens to be the venue for the trade, but the income is trading income, not property income. 

MTD Applies to Hotels

This matters for MTD because trading income is reported as self-employment, with different quarterly categories, and is subject to different rules (no property income allowance, but access to trading loss relief). The qualifying income still counts toward the MTD threshold. 

B&Bs With Owner Occupation 

A bed and breakfast where you live in part of the building and let guest rooms creates a mixed-use situation. The property expenses must be apportioned between the personal-use portion (your accommodation, not deductible) and the business-use portion (the guest rooms, deductible).  

The income is likely to be treated as trading income if you provide services, or property income if you let self-contained rooms without services. 

Serviced Accommodation and Holiday Cottages 

Since the abolition of the FHL regime on 6 April 2025 (under Finance Act 2024), all short-term furnished holiday lettings are treated as ordinary residential property income. This applies to Airbnb properties, holiday cottages, glamping pods, and any other short-term furnished let. 

Section 24 applies to their finance costs. They are residential, not commercial, for MTD purposes. If you previously reported these as FHL income with fully deductible mortgage interest, that treatment has ended and your quarterly categorisation must reflect the change. 

The exception is where you provide substantial services alongside the accommodation (daily cleaning, meals, reception), which may push the activity into trading income rather than property income. The distinction is fact-dependent and often disputed. Where there is any doubt, take professional advice before your first MTD filing. 

The Key Difference From Residential Landlords: No Section 24 Restriction

This is the single biggest difference between commercial and residential property under MTD, and it works in your favour. 

The Section 24 restriction, introduced by section 24 of the Finance (No. 2) Act 2015 and now operative through ITA 2007 sections 272A to 274, applies to residential property finance costs only.  

For residential property, mortgage interest is not deducted from rental profits. Instead, it is given as a basic-rate (20%) tax credit at the Final Declaration. For higher-rate and additional-rate taxpayers, this creates a genuine tax cost: income taxed at 40% or 45% with relief at only 20%. 

For commercial property, Section 24 does not apply. Your mortgage interest and other finance costs on non-residential property remain fully deductible against rental profits in the normal way. They reduce your taxable profit pound for pound, regardless of your marginal tax rate. 

Impact on Your MTD Quarterly Reporting  

Residential landlords below the VAT threshold report three figures each quarter: total income, total expenses (excluding finance costs), and residential property finance costs as a separate line.  

Commercial landlords below the VAT threshold report just two figures: total income and total expenses. Finance costs are included within total expenses because there is no Section 24 restriction to require separation. 

If you have both residential and commercial property, the mortgage interest must be split. Residential property mortgage interest goes into the residential property finance costs category. Commercial property mortgage interest goes into the non-residential property finance costs category, which is a normal deductible expense.  

If a single mortgage is secured across both residential and commercial properties, the interest must be apportioned on a reasonable basis. A split based on property values or loan amounts attributable to each type is the most common and defensible approach. 

Mixed-Use Properties: When Part of the Building Is Residential 

A building with a shop on the ground floor and a flat above is one of the most common property types in the UK, and one of the most commonly handled incorrectly under MTD. It is a mixed-use property: part residential, part non-residential. The income and expenses must be split between the two. 

mixed used properties

HMRC does not prescribe a single apportionment method. The two most common approaches are floor area and rental value. Floor area is the simplest: if the shop occupies 60% of the total floor area and the flat occupies 40%, the rent and expenses are split 60:40 between non-residential and residential.  

Rental value is more defensible where the commercial element commands a different rent per square foot than the residential element, but requires a valuation basis. 

Whichever method you choose, apply it consistently and document the basis. The apportionment determines how much of the mortgage interest is subject to Section 24 (the residential portion) and how much is fully deductible (the commercial portion). Getting this wrong affects every quarterly update and the Final Declaration. 

WORKED EXAMPLE

You own a building on a high street. The ground floor is let as a hairdresser's salon at £12,000 annual rent. The first floor is let as a residential flat at £9,600 annual rent. Total rent: £21,600. 

Apportionment on a rental-value basis: 55.6% commercial, 44.4% residential. 

Mortgage interest of £6,000 per year is split as follows. £3,336 is non-residential finance cost (fully deductible). £2,664 is residential finance cost (Section 24 basic-rate credit only). 

Each quarter, you report these as separate categories in your update. 

VAT and Commercial Property: How It Interacts With MTD

VAT is where commercial property gets complicated. Residential property income is exempt from VAT, full stop. But commercial property has a more nuanced position, and if you are VAT-registered or are considering it, the interaction with MTD needs careful thought. 

The Default Position 

The letting of commercial property is exempt from VAT by default, as per Gov.uk. You do not charge VAT on the rent, and you cannot reclaim VAT on expenses related to the property. Most small commercial landlords with one or two units and no other VAT-registered business will be in this position. 

The Option to Tax 

A commercial landlord can elect to tax a property by notifying HMRC. Once exercised under Schedule 10 of the Value Added Tax Act 1994, the rent on that property becomes subject to VAT at 20%, and the landlord can reclaim VAT on related expenses such as repairs, professional fees, and refurbishment costs. 

An option to tax is usually a long-term decision. In simple terms, once you opt to tax a commercial property, you normally have to charge VAT on the rent and you cannot easily change your mind.  

There is a limited six-month cooling-off period, but only if certain conditions are met. After that, you would usually need to wait at least 20 years before revoking the option. 

The option to tax can be useful where the landlord expects to incur significant VAT on costs, such as refurbishment works, repairs or professional fees. Charging VAT on the rent may not be a problem if the tenant is VAT-registered and can reclaim it.  

But if the tenant is not VAT-registered, the VAT becomes a real extra cost for them, which can make the property less attractive or harder to let. 

How the Two MTD Regimes Interact

MTD for Income Tax and MTD for VAT are two separate regimes.  

If you are VAT-registered and have opted to tax a commercial property, you are already filing VAT returns digitally under MTD for VAT, which has been mandatory since April 2019 for VAT-registered businesses above the threshold. MTD for Income Tax adds a second quarterly reporting obligation on top. 

The income and expenses reported under MTD for Income Tax should be the VAT-exclusive figures. If your quarterly rent is £10,000 plus £2,000 VAT, the MTD ITSA quarterly update reports £10,000 (the net figure), not £12,000. The VAT element is handled through your VAT return, not through MTD ITSA. 

If you are not VAT-registered and have not opted to tax, there is no VAT interaction. Your MTD ITSA reporting uses the actual amounts received and paid, which already exclude VAT because no VAT has been charged. 

Tip

If you have opted to tax a commercial property, the rent counts towards the VAT registration threshold. This is a common trap for landlords who also run a business. 

For Example

If your opted-to-tax commercial rent and sole trade turnover together exceed £90,000, you must register for VAT, assuming both income streams belong to you personally. Once registered, you may need to deal with MTD for VAT as well as MTD for Income Tax. These are separate reporting regimes, so your VAT returns and income tax updates must both be managed correctly.

Cash Basis or Accruals for Commercial Property 

Cash basis is the statutory default for unincorporated property income, and for most small commercial landlords it is the right choice. Income is recognised when received, expenses when paid. Quarterly updates report the cash position, and the workflow is straightforward. 

Commercial property has three characteristics that sometimes make accruals a better fit: 

  • Quarterly rent timing mismatches. Commercial rent is often paid quarterly, sometimes in advance on the traditional quarter days and sometimes in arrears. Under cash basis, the rent appears in the quarter it is received, which may not match the period it relates to. Under accruals, income is recognised when it falls due, which gives a more accurate picture each quarter. 

  • Capital allowances. If you want to claim Structures and Buildings Allowance or plant and machinery allowances, accruals basis is required (except for cars). On cash basis, qualifying capital expenditure is deducted when paid, which may produce a different timing of tax relief and forgoes SBA entirely. 

  • Large prepayments. Annual insurance premiums, business rates paid in one lump sum, and other large prepaid expenses can distort the cash basis position in the quarter they are paid. Accruals spread these costs more evenly. 

The choice is made at the start of each tax year and can be changed annually. You do not need HMRC approval. For most small landlords with one or two commercial units and no significant capital expenditure plans, cash basis is simpler and perfectly adequate. 

Capital Allowances 

Capital allowances are one area where commercial property has a significant advantage over residential property, and they interact with MTD in a specific way. 

Residential landlords cannot claim capital allowances on the property itself; they use Replacement of Domestic Items Relief for furnishings instead.  

Commercial landlords can claim: 

  • Structures and Buildings Allowance (SBA). A 3% annual writing-down allowance on the original construction or renovation cost of non-residential buildings, available for qualifying expenditure incurred on or after 29 October 2018 under CAA 2001 Part 2A. The rate has been 3% since April 2020. 

  • Plant and machinery allowances. Fixtures, heating systems, lifts, fire alarms, and other qualifying plant within a commercial building can attract capital allowances, including the Annual Investment Allowance (AIA) for the year of purchase. 

These allowances do not appear in your quarterly updates. Quarterly updates report income and expense category totals only. Capital allowances are computed and claimed at year-end in the Final Declaration. This means your in-year estimated tax position after each quarterly update will not reflect capital allowance claims. The accurate figure only emerges at year-end. 

If you are on cash basis (the default for most unincorporated landlords under (ITTOIA 2005 Chapter 17A), capital allowances are not available except for cars. Instead, qualifying capital expenditure is deducted as an expense when paid. Critically, SBA on qualifying buildings expenditure is not available on cash basis because it is structurally an annual writing-down allowance on capitalised expenditure.  

For commercial landlords with significant capital expenditure, particularly on structures and buildings, accruals basis may preserve a better tax outcome. This is worth discussing with your accountant before your first MTD filing year. 

Quarterly Updates for Commercial Landlords: What to Report

If your UK property income is below the VAT registration threshold, you may be able to use HMRC’s simplified reporting option. This means your quarterly update can usually show just total income and total expenses, rather than a detailed breakdown of every income and expense category. 

If your income is above the threshold, or you choose not to use simplified reporting, you must use HMRC’s full property categories. For commercial landlords, this means separating rent from other property income, such as service charges, lease premiums and reverse premiums, and categorising expenses under the correct headings.  

The expense side is set out below. 

HMRC category 

What it covers 

Total rent 

Rent received from all commercial properties 

Other income from property 

Service charges, premiums for granting a lease, reverse premiums 

Rent, rates, insurance, ground rents 

Business rates, property insurance, ground rent 

Property repairs and maintenance 

Revenue repairs (not capital improvements) 

Non-residential property finance costs 

Mortgage interest, loan interest, arrangement fees (fully deductible) 

Legal, management, professional fees 

Accountancy, surveyor, letting agent fees 

Cost of services provided, including wages 

If you employ anyone for property management 

Travel expenses 

Travel to and from properties for management purposes 

Other allowable property expenses 

Any other qualifying expense not covered above 

Note the category non-residential property finance costs. This is where your commercial mortgage interest goes. Unlike the residential property finance costs category, it is a straightforward deductible expense. No basic-rate credit, no year-end restriction. It reduces your profit directly. 

If you have both residential and commercial properties, all of them form one combined UK property business for MTD. But you must categorise the expenses correctly: residential finance costs in their category, non-residential finance costs in theirs. 

Common Mistakes for Commercial Landlords 

"Section 24 applies to my commercial property." 

It does not. Section 24 applies to residential property only. Your commercial mortgage interest is fully deductible. If you have been reporting it as a restricted cost, your quarterly updates have been wrong. 

"My holiday cottage is commercial property." 

Since the FHL abolition on 6 April 2025, short-term holiday lets are residential, not commercial. Section 24 applies to their finance costs. 

"My property is in a limited company, so MTD applies." 

MTD for Income Tax applies to individuals, not companies. If the commercial property is owned by a limited company, it is outside the scope of MTD ITSA. Only personally held property triggers the MTD obligation. 

"I opted to tax for VAT, so I report VAT-inclusive figures under MTD." 

MTD for Income Tax uses VAT-exclusive figures. The VAT element is reported through your VAT return. Report the net rent and net expenses in your quarterly updates. 

"I do not need to worry about capital allowances until year-end." 

That is correct for the quarterly updates. But you should be tracking qualifying expenditure during the year so the Final Declaration claim is ready. Do not leave it all to January. 

"My B&B income is property income." 

It might be trading income if you provide substantial services. The classification affects which quarterly categories you use and whether trading loss relief is available. Clarify the position before your first filing. 

"I can use the simpler categorisation regardless of income." 

The simpler categorisation easement for UK property income is available only below the VAT registration threshold (£90,000 gross). Above that, you must use the full category breakdown. 

What to Do Next 

Step 1: Confirm whether you are in scope 

Start by checking your qualifying income. For MTD, this means your total gross income from property and self-employment before expenses. 

Include your commercial rental income, any residential rental income and any sole trade turnover. If the combined total is above the threshold for your mandation year, you are within MTD for Income Tax. 

Step 2: Check how each property should be classified 

Review each property in your portfolio and confirm whether it is fully non-residential or partly residential. 

A shop, office or warehouse will usually be non-residential. A shop with a flat above, however, is mixed-use. This matters because the residential element may bring Section 24 into play for part of the finance costs. 

Step 3: Agree an apportionment method for mixed-use properties 

If you own a mixed-use building, decide how the income and expenses will be split between the residential and non-residential parts. 

The method should be reasonable, documented and applied consistently from the first MTD quarter. This split will affect both your quarterly updates and your year-end tax position. 

Step 4: Check the VAT position 

If you have opted to tax any commercial properties, make sure your MTD ITSA records use VAT-exclusive figures. 

The VAT charged to tenants belongs in your VAT return, not your income tax quarterly update. Your MTD ITSA figures should show the net rent and net expenses. 

Step 5: Review planned capital expenditure  

If you expect significant capital expenditure, such as refurbishment works or qualifying fixtures, consider whether the cash basis or accruals basis gives the better tax outcome. 

This is especially important where capital allowances may be available. The decision should be reviewed before your first MTD filing year, not after the expenditure has already been recorded. 

Step 6: Sign up for MTD for Income Tax   

Once you have confirmed that you are in scope, you need to sign up for MTD for Income Tax through your HMRC online account using Government Gateway. 

Your software cannot do this registration for you. The software can submit your quarterly updates once you are signed up, but the HMRC registration step must be completed separately. 

Where to go from here 

For the full picture on MTD ITSA, including thresholds, penalties, and the Final Declaration, see our main guide on MTD for Income Tax (MTD ITSA). 

For mixed portfolios with both residential and commercial property, our Making Tax Digital for Landlords guide covers the residential side. 

If you want to see how RentalBux handles mixed-portfolio categorisation, including the residential and non-residential finance cost split, start a free trial at app.rentalbux.com/register or book a walkthrough at rentalbux.com/book-demo.

Disclaimer

This guide is for general information only and does not constitute professional tax advice. UK tax legislation, HMRC guidance, and MTD requirements change. Always verify the current position with HMRC or a qualified adviser before acting. Information correct as of May 2026. 

FAQ Section

Do commercial and residential properties form one property business? 

Yes, for MTD purposes. All UK property income, whether residential or commercial, is reported as one UK property business. But you must categorise income and expenses correctly within that business, particularly the split between residential and non-residential finance costs. 

Can I claim repairs on my commercial property? 

Yes, the same revenue-versus-capital distinction applies. Repairs (restoring something to its previous condition) are deductible. Improvements (enhancing beyond the original) are capital expenditure. For commercial property, capital improvements may qualify for Structures and Buildings Allowance at 3% per year. 

What if I let a property partly furnished for commercial use? 

Furnishings in commercial property may qualify for plant and machinery capital allowances (not Replacement of Domestic Items Relief, which is residential only). The Annual Investment Allowance can cover the full cost in the year of purchase, subject to the annual limit. 

Does the £1,000 property income allowance apply to commercial property? 

Yes. The £1,000 property income allowance under sections 783A and 783B of ITTOIA 2005 applies to all property income, whether residential or commercial. But if you claim it, you cannot also claim expenses. For most commercial landlords with mortgage interest and other costs, claiming expenses is more beneficial. 

What about a garage let separately from a house? 

A standalone garage or parking space let separately is non-residential. Section 24 does not apply to the finance costs attributable to it. If it is let together with a residential property as part of the same tenancy, it follows the residential treatment. 

I own a farm and let some buildings commercially. Does MTD apply?

If you personally own the farm and the gross rental income from the commercial lettings, combined with any other qualifying income (self-employment, residential property), exceeds the threshold, yes. Farm buildings let for storage, workshops, or events are non-residential. 

Do I need different software for commercial property? 

No. Your MTD software should handle both residential and commercial property within one UK property business. The key requirement is that it supports the separate HMRC categories for non-residential finance costs and allows you to categorise expenses correctly. Check this before you commit. 

What if my tenant pays VAT on the rent but I am not VAT-registered? 

If you have not opted to tax and are not VAT-registered, you should not be charging VAT. If someone is paying you VAT on rent, there may be an error in the arrangement. Review the position with your accountant. 

Can I switch from cash basis to accruals mid-year? 

No. The choice is made at the start of the tax year and applies for the full year. You can switch at the start of the next tax year without HMRC approval. 

Are empty commercial properties still reported under MTD? 

If you have no income from the property, there is nothing to report in the quarterly updates. But expenses such as insurance, business rates, and security are still deductible and can be included. An empty property does not remove you from MTD if your other qualifying income keeps you above the threshold.

What if I get the first quarterly update wrong? 

HMRC has confirmed a soft-landing approach to late submission penalties for 2026/27, the first year of mandation. Genuine errors corrected before the Final Declaration are not penalised. The penalty regime applies from 2027/28 onwards. This does not remove the obligation to file on time, but it does reduce the risk of getting your first filing slightly wrong. 

RG

Raju Gajurel

Raju is a chartered accountant, chartered tax adviser and recognised Making Tax Digital expert with 23+ years advising property investors, developers and real estate funds, and author of the Accountant's Handbook on MTD used by hundreds of UK practitioners.

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