ATED: Why the April 2027 revaluation should be on your radar

Hillier Hopkins LLP

Chartered Accountants & Tax Advisers

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Although your company may not currently be within the scope of the Annual Tax on Enveloped Dwellings (ATED), now is the right time to start thinking ahead.

ATED is an annual tax that can apply where a company, a partnership with a corporate member, or certain collective investment schemes hold an interest in UK residential property valued at more than £500,000.

In many cases, businesses assume that if no return is required today, there is nothing to do. However, HM Revenue & Customs requires properties within these structures to be revalued on a five-year cycle, and the next key valuation date is 1 April 2027 (although valuations are also required on acquisition or when a property first comes within the regime). The value of a property at that date will determine whether an ATED return is needed for the 2027/28 chargeable period onwards, making early preparation an important part of good tax housekeeping.

For some companies, particularly those holding residential property that has appreciated in value over recent years, this could be the point at which a property moves into scope for the first time. Even where a property remains below the threshold, reviewing its position in advance can help avoid uncertainty, last-minute compliance issues and the risk of missed deadlines. ATED is often associated with high-value residential property held in corporate structures, but it is not only relevant to large portfolios or complex groups. A single dwelling can trigger the rules if it is owned by the right type of entity and its value exceeds the threshold. The definition of a dwelling is broad and can include houses and flats, together with gardens and grounds, although some property types fall outside the regime altogether.

It is also important to remember that reliefs may be available in certain circumstances, for example where a property is let commercially to an unconnected third party or held for property development purposes, but these reliefs are not automatic and may still require a return to be submitted. In other words, the absence of a tax charge does not always mean the absence of a filing obligation. That is why the upcoming revaluation date matters, even for businesses that have never previously needed to engage with ATED. A fresh valuation before 1 April 2027 could confirm that no action is needed, but it could equally identify that a property has crossed the threshold and that a return will be required.

For companies already within the regime, the revaluation may also affect the valuation band into which a property falls, which in turn can alter the amount payable. Taking advice before the valuation date, or soon afterwards, can help ensure that any assessment is robust and that the right compliance steps are taken at the right time. As with many areas of property taxation, small changes in facts or timing can have wider consequences, so a clear review of ownership, use and value is worthwhile. If your company owns UK residential property, now is a sensible opportunity to review whether the 1 April 2027 revaluation could affect your ATED position from 2027/28 onwards. Planning ahead can make the process more straightforward and reduce the likelihood of unexpected liabilities or administrative pressure later.

If you would like to discuss how the rules apply to your circumstances, or if you would like support with reviewing property values and potential filing requirements, please get in touch and we will be happy to help.

Do you need extra information?

Simon Cyna - Mixed Tax Senior at Hillier Hopkins

Simon has a vast amount of knowledge and experience covering all taxes but specialises in SDLT queries and general/advisory tax queries.

Contact Simon at simon.cyna@hhllp.co.uk or on +44 (0)1923 634 258

Based at the following office - Watford