Annual Tax on Enveloped Dwellings (“ATED”).

What is ATED?

• Since 1 April 2013, an annual tax charge has applied to “high-value” UK residential property owned by certain “non-natural persons”. This is known as the Annual Tax on Enveloped Dwellings (“ATED”) charge.

• The charge broadly applies to UK residential properties which are worth more than £0.5m.

Returns and payment

Where an ATED charge applies, a Tax Return and the associated payment will be usually required by 30 April in the year for which the charge applies, i.e. 30 April 2024 for the period 1 April 2024 to 31 March 2025. Different rules apply where e.g. a property is acquired part-way through a year, however. Penalties and interest apply where payment and or filing dates are missed.

Certain categories of buildings, e.g. hotels, guest houses and care homes are not classified as dwellings, so don’t fall within the ATED regime, and a number of further reliefs (most notably for commercial lettings and development activity) may be claimed. At present, these can only be claimed by completing and submitting an ATED Tax Return.

Rate bands

The current ATED charges are set out below.

Valuation of property

You must revalue your property every 5 years in line with ATED legislation.

The 2023 to 2024 chargeable period was a revaluation year.

If you acquired a property:

• on or before 1 April 2022 – use 1 April 2022 as the revaluation date
  
  
• after 1 April 2022 – use the date you acquired it as the valuation date

Valuation is principally a matter of self-assessment, we recommend a professional valuation is used when a revaluation is required.

How we can help

We can help with the following:

• Assessing whether your dwelling is subject to ATED
• Registration and filing of ATED returns
• Advising on possible restructuring to take a property out of the ATED charge
• Tax efficient structures for acquiring UK property interests and for UK property businesses

Please contact us to speak to an advisor about the ATED regime and how it may affect you.