One of my client received the following email from the ban
I am meeting various lenders over the next couple of days regarding your proposition. Lenders do not generally like to lend to trading limited companies, the best way forward is probably for you to create an SPV company purely to purchase the properties, we can help to do this for you. However could you ask your accountant what the tax position would be if you create the SPV and transfer the monies from your existing company to the SPV by means of an inter company loan, I believe the transfer would not be taxable but you should check with your accountant.
Can someone please advise what would be the tax implication of the loan to SPV?