Annual Tax on Enveloped Property

Residential properties are normally owned by individuals, but sometimes they are owned by companies, investment collectives or partnerships for commercial purposes. Such properties are said to be 'enveloped' because they are owned by a corporate entity

Annual Tax on Enveloped Dwellings (previously called Annual Residential Property tax) is payable on certain high-value (currently worth more than £500,000), enveloped properties. You will need to complete an Annual Tax on Enveloped Dwellings (ATED) return and pay any tax due (between £3,600 to £226,950) depending on your valuation band, if your property meets all of the following criteria:

  • is a residential property
  • is in the UK
  • is owned completely or partially by a corporate entity such as a company, a partnership where one of the partners is a company, or a 'collective investment vehicle' - for example, a unit trust or an open ended investment company
  • was valued or revalued at more than £500.000 on 1 April 2017. Prior returns use the 1 April 2012 valuation date. The starting valuation threshold was higher in earlier years (£1 million for 2015/16 returns: £2 million for 2013/14 returns) but has remained at £500k since 1 April 2016.

There are certain exemptions and reliefs that can reduce or eliminate ATED.

Who must pay ATED?

ATED is payable if the property is owned by a company, corporate body, collective investment vehicle (such as a unit trust). It is also payable by partnerships which contain companies, corporate bodies or investment vehicles. It is not payable by individuals who own residential properties directly.

ATED is also not payable by owners of hotels, guest houses, hospitals, care homes, student halls of residence, boarding school accommodation, military accommodation or prisons. It is not payable on properties located outside the UK. There are also reliefs available that may reduce ATED to nil. These include (but are not limited to):

  • commercial farming companies which own a farmhouse occupied by a 'farm worker' connected to the owning company
  • companies owning an historic house for commercial purposes which is open to the public or provides access to the dwelling for at least 28 days per year as part of its service (for example, as a wedding venue)
  • charities using a dwelling for charitable purpose
  • properties owned by a social housing provider
  • let to a third party on a commercial basis
  • being developed for resale by a property developer

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