ATED for non-resident companies
The Annual Tax on Enveloped Dwellings (ATED) came into effect from 1 April 2013. The tax applies to certain Non-Natural Persons (NNPs) that own interests in dwellings valued at more than £500,000. These provisions affect most companies, partnerships with company members and collective investment schemes. For the purposes of the ATED, it is immaterial whether the company, partnership or collective investment scheme is incorporated or resident in the United Kingdom. HMRC’s technical guidance on the subject states that, a company that is not...