Official Statistics

Annual UK ATED Statistics Commentary

Updated 31 March 2021

1. About this release

This publication provides annual statistics on receipts and liable declarations for Annual Tax on Enveloped Dwellings (ATED). This includes the whole of the UK. Data is split by price band, region, local authority and type of relief. For key definitions, guidance and references see the published tables (spreadsheet) that accompany this document.

It should be noted that this report only covers the period up to the end of 2019-20 and as such is not thought to include any real COVID-19 impact.

2. Background about Annual Tax on Enveloped Dwellings (ATED)

At Budget 2012 the Chancellor announced a set of measures to combat Stamp Duty Land Tax (SDLT) avoidance. These included ATED, a new annually recurring tax on UK residential dwellings which are held in a ‘corporate envelope’ (e.g. a company)

3. Key Summary

• ATED receipts in 2019-20 were £128 million. This is 8% (£11m) lower compared to the previous year, with decreases in all price bands except the £500K to £1m range which remained the same as the previous year.

• The number of liable ATED declarations in 2019-20 was 5,760, decreasing by 9% compared to the previous year, with decreases across all price bands, except the over £20m band, which was static.

• About 86% of ATED receipts are from London, which is the same as it was in 2018-19. The London boroughs of Westminster, followed by Kensington and Chelsea, still dominate the receipts by location for ATED.

• Between 2018-19 and 2019-20 there has been a 6% (1,240) increase in the number of relief declarations being made.

• All types of relief declarations have continued to rise, with the most notable rise being for Rental Relief, which accounts for 78% of all the relief claims made in 2019-20.

4. Estimated ATED receipts by band

Chart 1 below shows the amount of ATED receipts by the band the value of the corresponding property falls into. Liable declarations include those which were liable for only part of the year, for example, when a property is sold. It should be noted that the declaration numbers relate to specific tax years, but receipts figures relate to the actual year the payment was received. This chart shows that receipts have decreased for all valuation bands over £1m in the last year.

Estimated ATED receipts by band

4.1 Key points

• ATED receipts in 2019-20 were down by 8% (£11m) compared to 2018-19.

• There was a fall in receipts for all price bands except the £500K to £1m range, which remained stable.

• The largest fall in receipts was in the ‘£2m to £5m’ band, which had a fall of 14% (£5m).

How does ATED apply

ATED is a tax charged on ‘non-natural persons’ holding an interest in one or more residential properties in the UK. An ATED Tax return must be completed with respect to a property if all of the following apply. It’s a dwelling, completely or partly owned by a non-natural person, situated in the UK. Which was valued at more than:

• £2 million, or at acquisition if later, for returns from April 2013 onwards,
• £1 million, or at acquisition if later, for returns from April 2015 onwards
• £500,000, or at acquisition if later for returns from April 2016 onwards.

Where a non-natural person Is a company, a partnership where one of the partners is a company, or a ‘collective investment scheme’ (for example, a unit trust or an open-ended investment company).

The annual ATED charge is based on the value at the valuation date or the price as at the date of acquisition if that was more recent. For the period up to 2017-18 the valuation date was 1st April 2012. From 2018-19 onwards the new valuation date was 1st April 2017.

5. Estimated ATED liable declarations by band

Chart 2 below shows the number of ATED liable declarations by the band that the value of the corresponding property falls into. Liable declarations include those which were liable for only part of the year, which can occur, for example, when a property is sold. The number of liable returns have continued to fall across all bands during the last year with the exception of the over £20m valuation band which remained unchanged since 2018-19.

Estimated ATED liable declarations by band

5.1 Key points

• The number of ATED liable declarations decreased by 9% from 2018-19 to 2019-20, from 6,330 to 5,760. The decrease in liable declarations occurs in every band except the ‘Over £20m’ band, which was stable. The steepest fall (14%) in declarations was in the ‘£2m-£5m’ band. This fall in liable declarations can in part explain the fall in receipts.

• The profile of liable declarations across all price bands remained relatively consistent when compared to the previous year.

6. Estimated ATED Receipts by Region

Chart 3 shows the regional breakdown of receipts by percentage for the seven financial years from 2013-14 to 2019-20. The geographical breakdown of receipts in 2019-20 closely mirrors the breakdown in previous years.

Estimated ATED Receipts by Region

6.1 Key points

• Receipts from ATED declarations for properties known to be in London accounted for 84% of all receipts in 2019-20, a similar figure to last year, by far the highest of all regions.

• Looking at those where region is identifiable (excluding missing cases) 86% of the receipts where in London.

• Overall the regional breakdown appears broadly stable when compared to previous years, with the South East at 9%, the East of England, the South West, and the combined remainder of the UK at 2% each. The percentages of non-missing receipts were similar for non-London categories too.

• Missing regions, account for about £2m (2%) of receipts in 2019-20, a fall from the £4m (3%) figure reported in 2018-19. Missing regions occur generally because the address details reported are incomplete.

• It is not possible to provide a breakdown of receipts for all regions in the UK as this would breach HMRC’s policy on disclosure and taxpayer confidentiality.

7. ATED Receipts by Local Geographical Area

Chart 4 shows the local authority geographical breakdown of receipts by percentage for the seven financial years from 2013-14 to 2019-20. As in previous years the London boroughs of Westminster and Kensington and Chelsea continue to account for the vast majority of all ATED receipts.

ATED Receipts by Local Geographical Area

7.1 Key points

• ATED receipts where a geographical area was known were highest within the London Borough of Westminster accounting for 49% of ATED receipts in 2019-20, with a further 25% of receipts coming from declarations in the London Borough of Kensington and Chelsea, both of these are similar to the figures reported in 2018-19. The top 10 local authorities are the same as last year although the order has changed slightly with receipts for Elmbridge, Wandsworth, and ‘the rest of the UK’ decreasing by £1m in 2019-20 compared to 2018-19.

• The proportion of total receipts from these top two London boroughs in 2019-20 was very similar to those shown for the last few years.

• It is not possible to provide a comprehensive breakdown of receipts for all Local Authorities, or smaller geographies in the UK as this would breach HMRC’s policy on disclosure and taxpayer confidentiality.

8. ATED Relief Declarations by Type

There are a number of reliefs available which may reduce a non-natural person’s ATED liability to nil. These are claimed by stating on the ATED return the relief that applies. Any changes to the relief status of a property have to be stated on a new return.

It is not possible to provide a breakdown of receipts for all relief claims in the UK as this would breach HMRC’s policy on disclosure and taxpayer confidentiality.

Chart 5 shows the number of ATED relief declarations for the seven-year period from 2013-14 to 2019-20. This shows a year on year increase in relief declarations for all types of reliefs. As in previous years Rental relief continues to dominate the type of reliefs being claimed.

ATED Relief Declarations by Type

8.1 Key points

• There was a total of 20,910 relief declarations in 2019-20, an increase of 1,240 (6%) from 2018-19. This is a much smaller increase to the 22% increase in the previous year. Year on year comparisons on reliefs should be treated with particular caution, especially in relation to changes in the population that fall within the scope of ATED.

• The increase in reliefs in 2018-19 and 2019-20, particularly the rental relief, is likely to be from landlords incorporating. This is likely to be due to financial planning following changes in how mortgage interest expenses can be claimed from 2018-19. Also, tax campaigns reminding taxpayers and their agents of the need to complete a return even if no liability is due, may have had a significant impact on the number of declarations. Changes in Anti-Money Laundering Regulations and EU exit are also likely to lead to increasing levels of compliance even where no tax is due.

• About 78% of all relief claims in 2019-20 related to the rental relief (16,270 claims). The next highest was the property development relief accounting for 13% of claims (2,820 claims). The other types of reliefs came to about 9% of claims (1,820). The percentages for types of reliefs claimed in 2018-19 were similar to those reported for 2019-20.

• A full list of relief categories can be found in the supporting tables for this publication.

Contact information

E-mail stamptaxes.statistics@hmrc.gov.uk

Website https://www.gov.uk/government/collections/stamp-duties-statistics

Contacts

• Charles Sharry 03000 589 605
• Paul DMello 03000 517 149
• Media 03000 585 024