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Annual Tax on Enveloped Dwellings

ATED is an unconventional and surprisingly complicated tax. David Wright (ATT) recaps the basics and looks at the available reliefs.

A suite of anti-avoidance measures were introduced by FA 2013 aimed at reducing the tax efficiency previously offered by holding UK residential property in a corporate wrapper (or ‘envelope’). The Annual Tax on Enveloped Dwellings (ATED) was one such measure.

This article recaps the ATED rules and requirements: when it applies how the charge is calculated what reliefs are available and what the compliance process involves.

The following is intended as an overview of ATED only and professional advice should be sought regarding any possible ATED obligations.

What is ATED?

ATED is an annual charge payable where a ‘non-natural person’ (NNP) holds an interest in a high value UK residential property.

NNPs include companies partnerships with at least one corporate member...

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