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CIS for landlords

What if a landlord buys property to improve and add to portfolio, but changes mind at end?

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A landlord with a property portfolio buys a property to convert into flats and add to his rental portfolio. He pays various 'subcontractors' to undertake the work.

At the end of the conversion he decides that he is going to sell the flats rather than rent them.

What are readers views as to the CIS omplications? Should he have registered under CIS as a main contractor, being a property developer, even though that wasn't his intention?