Tax situation regarding solar panel installation in large residential estate

Our client manages a large private residential estate in London. The bank are willing to fund a £450,000 solar panel installation, but are insisting that a separate Ltd Co be set up to ringfence the project. Presumably that will be a company limited by guarantee.

Can anyone shed any light on the tax situation? The Ltd Co will be receiving the feed in tariff and the payments for surplus production being exported to the grid. Will the FIT retain its domestic tax-free status within a company (this is an entirely domestic site)? Are the export receipts taxable? To the extent that the various incentive payments fall short of the company's loan repayment and equipment maintenance obligations, the service charge fund itself will need to contribute to the Ltd Co's coffers. Will this income be taxable? The Ltd Co is sure to make an accounting profit for the first few years as much of the contribution from the service charge fund will go to pay the capital of the loan.

Although this is not a trade, I can't help thinking that the existence of 3rd party income (from Govt and electricity companies) must be relevant. All help gratefully received!