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Home / Simons-Taxes /Business tax /Part B6 Property income and taxes /Division B6.7 Annual tax on enveloped dwellings (ATED) /ATED—chargeable interests and 'single-dwelling interest' / B6.722 ATED—interests held by connected persons
Commentary

B6.722 ATED—interests held by connected persons

Business tax

ATED is charged in respect of 'single-dwelling interests' (SDIs), which are defined at B6.720. This article covers the ATED consequences where on any day entitlements to separate SDIs in the same dwelling are held by connected persons (eg two companies holding separate interests in the same dwelling where both companies are wholly owned by another person). The definition of connected persons is discussed at B6.703.

The general rule is that ATED applies as if each is entitled to the other person's single-dwelling interest as well as their own1. The effects of this rule are that2:

  1. Ìý

    •ÌýÌýÌýÌý each person is treated as entitled to a single SDI consisting of the two separate interests (applying the rules at B6.721)

  2. Ìý

    •ÌýÌýÌýÌý they are treated as jointly entitled to the single SDI and ATED is charged only once for any day in respect of it (see B6.706)

  3. Ìý

    •ÌýÌýÌýÌý the two persons are jointly and severally liable to the ATED (see B6.706)

  4. Ìý

    •ÌýÌýÌýÌý only one ATED return is required for each

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