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ATED: a reminder

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‘No tax’ doesn’t always mean ‘no filing’.

The Annual Tax on Enveloped Dwellings (ATED) applies to ’non‑natural persons’ (for example, companies) that own UK residential property valued at more than £500,000. ATED operates on a forward‑looking basis, with each chargeable period running from 1 April to 31 March.

The amount of ATED payable is determined by the market value of each dwelling at specific statutory valuation dates or other relevant events and applies until the taxpayer ceases to fall within the regime.

While ATED is charged daily, taxpayers must either pay the ATED charge or claim a relevant relief at the start of each chargeable period. Relief from the charge is not automatic. To benefit from it, the taxpayer must self‑assess and file an ATED relief declaration return (RDR) each year, confirming that the conditions for the applicable ATED relief are met for the remainder of the chargeable period.

ATED compliance obligations for 2026/27: The 2026/27 chargeable period began on 1 April 2026, meaning that 2026/27 ATED filings are due with HMRC by 30 April 2026.

Where a taxpayer is already within ATED:

  • if ATED is payable, an ATED return must be filed and the tax paid for each dwelling no later than 30 April 2026. Late filing or payment can result in tax‑geared penalties and interest; or
  • if no ATED is payable because a relief applies, an ATED RDR must still be submitted by 30 April 2026. Failure to do so can trigger fixed late filing penalties, even where no tax is ultimately due.

Taxpayers should also monitor ownership and use of dwellings throughout the chargeable period. As ATED is assessed on a daily basis, changes in ownership or use of a property during the year (for example, a move out of a qualifying relief) may trigger a new or amended filing part‑way through the chargeable period.

Properties valued below £500,000: Where an entity holds dwellings that are currently valued at £500,000 or less, no ATED filing is required for the 2026/27 period. However, entities should note that the next ATED statutory revaluation date is 1 April 2027. At that point, dwellings (including those under construction) must be re‑assessed. If a property exceeds £500,000 at that date, ATED obligations could arise from 1 April 2028, unless another earlier event brings the entity into scope.

What action should be considered? Entities holding UK residential property through corporate structures should:

  • check whether ATED filings or relief declarations are required for 2026/27;
  • review whether property use still meets the conditions for any claimed ATED relief; and
  • identify upcoming valuation points or events that could bring a property into scope.

Where ATED obligations may have been missed in earlier years, these should be addressed proactively: obligations can continue to apply even after a property has been sold. Early review can help manage penalties, interest and wider risk. 

Preema Patel & Michael Hope, KPMG

Issue: 1750
Categories: In brief
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