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B6.725 ATED—meaning of 'dwelling'

As indicated in B6.705, ATED applies to residential properties ('dwellings') that are physically located in the UK. It is charged on single-dwelling interests (SDIs). The meaning of an SDI therefore depends firstly on identifying a 'dwelling'. This article discusses the meaning of 'dwelling': broadly, a dwelling may be all or part of a residential or mixed-use property and includes gardens and grounds and any building within them.

A building or part of a building counts as a dwelling at any time when:

1. Ìý

   •ÌýÌýÌýÌý it is used or suitable for use as a single dwelling, or

2. Ìý

   •ÌýÌýÌýÌý it is in the process of being constructed or adapted for such use¹

A 'single dwelling' takes its ordinary meaning as a distinct unit of residential property, ie a house or flat which is considered as one residence².

Whether a property is 'suitable for use as a dwelling' is a question of fact and is based broadly on the same concept that exists for SDLT³. If a building