New nudge letter on ATED avoidance qualifying property business relief

In its latest ‘one to many’ letter campaign HMRC are writing to offshore corporates who owned UK residential property over £500 000 but were registered and reported consecutive losses on their self-assessment returns from their property rental income from 2017/18 to 2019/20.

This comprises of four letters: one for companies that have filed for Annual Tax on Enveloped Dwellings (ATED) property rental business relief one for companies that have not with variations of both letters for the represented and unrepresented.

The letters encourage companies to file outstanding ATED returns for anything owed and not already paid/reported and to correct their position going forward with a view to companies and representatives reassessing their loss-making UK rental businesses and register for ATED and file all applicable ATED liability returns. HMRC intend to continue to issue these letters in small tranches/numbers over the next few months and will continue...