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All sealed up

18 November 2014 / Stephen Hemmings
Issue: 4478 / Categories: Comment & Analysis , ATED , Capital Gains , Investments , Land & property
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What to look for in the changing face of the ATED

KEY POINTS

  • The ATED charge is designed to counter the advantages of holding UK residential property in a non-UK company.
  • There are three targeted structures and three potential tax liabilities.
  • Note that the thresholds when the annual charge and capital gains tax apply are reducing from £2m to £500 000.
  • If a business qualifies for relief from the annual tax it must still file an annual return.
  • Although the annual charge is raising more than originally estimated owners may feel that it is a small price to pay to preserve other tax benefits.

The annual tax on enveloped dwellings (ATED) was initially introduced to eliminate any tax advantages from holding high-value homes in a corporate structure. However the complex rules have created confusion for clients holding...

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