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B6.701 Annual tax on enveloped dwellings (ATED)—overview

The annual tax on enveloped dwellings (ATED), as the name suggests, is a tax which applies annually to UK residential property held by a company, a partnership which includes a company or a collective investment scheme. It applies only if the value of the property is more than £500,000. Where an interest (a 'single-dwelling interest' or SDI) in a property is within the charge throughout a chargeable period (running from 1 April each year), the tax is a fixed amount determined according to the band into which the value of the property falls. The amount of the charge is reduced where the property is acquired or disposed of during a chargeable period and there are various reliefs primarily aimed at genuine commercial businesses which eliminate the charge. If a relief applies for only part of a chargeable period, the charge is reduced proportionately rather then eliminated entirely.

HMRC has published technical guidance on ATED and made