ATED and Company Ownership

ATED is charged for each chargeable period running from 1 April to 31 March, on each dwelling separately. The charge is banded by the property's value, and the band is set by a valuation rather than by the price you paid — properties are revalued on fixed dates and the valuation carries forward until the next revaluation date.

For the 2026-27 chargeable period, a dwelling valued in the £2m–£5m band attracts a charge of £32,200. Higher bands carry substantially higher charges and lower bands lower ones; the current full band table is published on GOV.UK and is uprated most years.

The return is due, and the tax payable, by 30 April at the start of the chargeable period — in other words, in advance. A company that buys mid-year files within 30 days of acquisition and pays a pro-rated charge.

Most enveloped property in genuine commercial use pays no ATED at all. The reliefs cover, among other things, dwellings let commercially to unconnected third parties, property held as trading stock by a developer, property held for a property-dealing business, farmhouses, and dwellings open to the public.

The trap is procedural rather than substantive. A relief only applies if it is claimed, and it is claimed on a Relief Declaration Return filed for each relief, for each chargeable period. Miss the filing and HMRC can charge penalties even though no tax was ever due. Companies that let a London flat to an unconnected tenant year after year still need a return every single year.

The reliefs are also conditional on the facts staying true. If a let property is occupied by a connected person — a shareholder, a director, a family member — even briefly, the relief can fall away for that period and the charge revives.

• Let commercially to a third party unconnected with the owner
• Held as stock of a property development or property trading business
• Open to the public for at least 28 days a year
• A farmhouse occupied by a working farmer
• Held by a provider of social housing or for employee accommodation

The annual charge is only the recurring half of the cost. A company buying a single dwelling for more than £500,000 pays SDLT at a flat 17% of the whole price, or 19% where the company is non-UK resident. At £2,000,000 that is £340,000 or £380,000 — against £253,750 for an individual buying the same property as an additional home.

There is an SDLT relief for companies acquiring property for a qualifying rental business, which restores the ordinary banded rates plus the additional-dwelling surcharge. It is worth having, but it is conditional and can be withdrawn if the qualifying use stops within the clawback period.

Combine the entry charge and the annual charge and the envelope has to be earning its keep. It rarely does for a single family home that nobody lets.

A separate annual charge on high-value homes — the High Value Council Tax Surcharge — applies from April 2028. It runs from £2,500 to £7,500 a year depending on band, based on 2026 valuations, and it is not limited to enveloped property: it lands on the home regardless of who owns it.

For a £2 million property held in a company, that means the ATED charge and the new surcharge stack from 2028 onwards. Any ten-year model written today should carry both.

Corporate ownership has not disappeared, but the reasons for it have narrowed. It still has a role where a portfolio is genuinely let and the ATED letting relief applies, where finance costs matter and the corporate interest treatment is more favourable than the restricted relief individuals get, or where succession and share-transfer mechanics are the point rather than the tax.

It works badly where the property is a personal residence, occupied by the owner or family, held for capital growth alone, or where nobody has budgeted for annual compliance. Unwinding an envelope later is expensive: extracting the property can trigger tax at both company and shareholder level.

Decide the structure before you exchange. Changing it afterwards means paying the entry costs twice.

Recurring costs only — the SDLT entry charge is separate. Figures current as at August 2026.

Figures current as at August 2026.

Worked Example: Ten Years in a Non-Resident Company

A non-UK resident company buys a £2,000,000 London flat and holds it as a family residence, so no ATED relief is available.

£380,000 + £322,000 = £702,000, against £293,750 personally — a difference of £408,250 before professional fees, and before the High Value Council Tax Surcharge lands in April 2028. ATED is uprated most years, so a ten-year total at a flat £32,200 is conservative.

Every figure on this page is taken from the following official guidance, checked on 15 August 2026.

• GOV.UK: Annual Tax on Enveloped Dwellings — the basics
• GOV.UK: Stamp Duty Land Tax — residential property rates
• GOV.UK: Rates of Stamp Duty Land Tax for non-UK residents