ATED

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What is the annual tax on enveloped dwellings?

The annual tax on enveloped dwellings (ATED) was introduced as part of a package of measures aimed at making it less attractive to hold high-value UK residential property indirectly, eg through a company, in order to avoid or minimise taxes such as stamp duty land tax (SDLT) on a subsequent disposal of the property.

The other measures included in the anti-avoidance package relating to high-value UK residential property include:

  1. •

    the single higher rate of SDLT on the acquisition of high-value UK residential property for non-natural persons (NNPs) (for further details, see Practice Notes: Rates of SDLT and Single higher rate of SDLT for high-value residential property transactions), and

  2. •

    prior to 6 April 2019, a capital gains tax (CGT) charge on sales of high-value UK residential property by NNPs (abolished from 6 April 2019) (for further details, see Practice Note: Capital gains tax charge on ATED-related gains [Archived])

When does ATED apply?

The provisions enacting ATED are set out in Part 3 of the Finance Act 2013 (FA 2013). ATED ...

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Most recent ATED content

Practice notes

Capital gains tax charge on ATED-related gains [Archived]

Capital gains tax charge on ATED-related gains [Archived]ARCHIVED: This Practice Note has been archived and is not maintained.The annual tax on...
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10th Feb
Practice notes

ATED—reliefs and exemptions

ATED—reliefs and exemptionsWhat reliefs and exemptions are available?The basic charge to annual tax on enveloped dwellings (ATED) is explained in...
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10th Feb
Practice notes

ATED—administration and payment of tax

ATED—administration and payment of taxThe basic charge to ATED is explained in Practice Note: ATED—the basics. This Practice Note summarises how ATED...
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10th Feb
Practice notes

Annual tax on enveloped dwellings (ATED)—the basics

Annual tax on enveloped dwellings (ATED)—the basicsWhat is the annual tax on enveloped dwellings?The annual tax on enveloped dwellings (ATED) was...
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9th Feb
Q&As

Where trustees hold shares in a company and also hold the title to a UK residential property as a nominee for the company, what are the tax implications of a restructure whereby the company would be wound up and the trustees would simply hold the UK residential property legally and on the terms of the trust?

Where trustees hold shares in a company and also hold the title to a UK residential property as a nominee for the company, what are the tax...
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16th Jul
Q&As

Does annual tax on enveloped dwellings apply to a limited company housebuilder that acquires existing dwellings for conversion or demolition and re-build?

Does annual tax on enveloped dwellings apply to a limited company housebuilder that acquires existing dwellings for conversion or demolition and...
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27th Apr
Q&As

In order to qualify for property rental business relief from ATED, must the company’s sole purpose be a property rental business or may the company also have another purpose (eg a dental practice)?

In order to qualify for property rental business relief from ATED, must the company’s sole purpose be a property rental business or may the company...
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27th Apr

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