Pension-capable property, engineered — never self-certified.
Most 'SIPP-able' room-sale products quietly fail HMRC's rules — residential on inspection, furnished (taxable tangible moveable property), and rejected by administrators. Keystone engineers the product to fit the exemptions instead: commercial interests in the registered care homes (the care-institution exemption) and rooms in the Greenock hostel (the hotel/hostel exemption) — unfurnished, no personal use, FRI-leased — and we put the rules, and the real gatekeeper, in front of you before anything else.
Three things to know.
Two engineered routes — and only two
Registered care homes under the care-institution exemption, and the Greenock hostel under the hotel/inn/similar-establishment exemption. Never self-contained flats, never a furnished 'care suite'. That distinction is the whole HMRC game, and we never blur it.
Analysis first, opinion where it matters
Keystone's in-house eligibility analysis maps every unit type to HMRC's tests (FA 2004 Sch 29A; PTM125000+), with a written tax opinion on the care homes — in progress, not yet confirmed. Until the gates clear, we register interest only.
Your administrator is the gatekeeper
"SIPP compliant" isn't a status anyone grants themselves. Your SIPP/SSAS administrator's technical team assesses the asset and their written acceptance decides — and HMRC always has the final say. Keystone never gives pension advice and never suggests moving a pension.
Four gates, in order.
Pension money does not move until all four are cleared — and the decisive one belongs to your administrator, not to us.
- 1Eligibility analysis & opinion
Keystone's in-house analysis maps each unit type to HMRC's tests (FA 2004 Sch 29A; PTM125000+) — with a written specialist opinion on the care homes, and counsel escalation only where genuinely borderline.
- 2Your adviser
Your own regulated adviser assesses suitability. Keystone provides the data room and answers — never advice, never transfer encouragement.
- 3Your administrator's acceptance
The gatekeeper, and non-negotiable: your SIPP operator or SSAS trustees' technical team assesses the asset and their written acceptance decides. We work to their requirements.
- 4Administrator-led completion
The purchase completes through your scheme administrator and solicitors — unfurnished (no furniture in a pension), no personal-use rights, rent paid to the scheme.
Why the caution: furnished “care suite” room products sold as “SIPP-able” are the structure behind the sector's mis-selling failures — residential on inspection, furniture creating taxable tangible moveable property, and ultimately rejected by providers. Keystone's pathway is designed so that cannot happen here.
The eligibility decision tree
FA 2004 Sch 29A · HMRC PTM125000+Our in-house analysis, shown rather than asserted. Walk the branch for the product you are considering — and note that every branch that survives still ends at the same gate.
What would the pension hold?
Commercial interest in a registered care home
Sch 29A excludes “a home or other institution providing residential accommodation with personal care” — the care-institution exemption. Four tests, all engineered in:
- ✓A commercial interest in the registered home — never a self-contained dwelling
- ✓No personal-use or occupation rights for you or anyone connected to you
- ✓Unfurnished — furniture in a pension is taxable tangible moveable property
- ✓Genuine commercial operation: one FRI operator lease, rent paid to the scheme
Room in the Greenock hostel
Sch 29A also excludes “a hotel or inn or similar establishment” — which HMRC's guidance extends to hostels. The structure is engineered to sit inside it:
- ✓Operator-run hotel-and-hostel use — not a dwelling
- ✓Rooms are not self-contained dwellings; one operator lease across the building
- ✓The hotel-room trap: any occupation or use right for the member or connected persons fails the exemption — so there are none, ever
- ✓Unfurnished for pension buyers; rent paid to the scheme
Self-contained apartment
A self-contained flat is residential property on HMRC's tests no matter how it is marketed. There is no branch to walk:
- ✕“Used or suitable for use as a dwelling” — fails at the first question
- ✕No exclusion applies — furnished “care suite” labels do not change the analysis
Every surviving branch ends here: your administrator's written acceptance.
The gate — never self-certified“SIPP compliant” is not a status Keystone — or any seller — can grant itself. Your SIPP operator or SSAS trustees' technical team assesses the asset against their own criteria, and their written acceptance, not our analysis, decides whether your scheme can hold it. HMRC always retains the final, retrospective say. The purchase itself completes through your scheme administrator and solicitors, never online.
Register pension interest.
Talk to the team — not a call centre. A reply within one business day, the data room for certified investors, and the AI concierge on every scheme page for instant answers.
Scheme overview & live availability
Unit schedule, status and the build programme.
Lease heads of terms
FRI structure, CPI-linked rent reviews (collared and capped), operator covenant note.
The compliance pack
SRA-escrow deposit route, RICS valuation process, title structure.
A named contact
One person who knows the schemes — never a call centre.
Illustrative, assumptions-based figures. The operator could fail. Resale takes time. Values can fall. Yields and exit pricing are not guaranteed. Capital at risk. Not advice.