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Annual tax on enveloped dwellings and stamp duty land tax interactions

07 February 2023 / Rob Durrant-Walker
Issue: 4875 / Categories: Comment & Analysis , ATED , SDLT , Land & property
Fiddler on the roof

Key points

  • Stamp duty land tax is a tax on acquisition while the annual tax on enveloped dwellings is an annual property tax but is also a tax on acquisition and sale.
  • Scotland and Wales also have ATED but do not have ATED-related SDLT.
  • Hybrid ownership propositions between connected parties are more complex.
  • Try to spot the higher ATED-related SDLT outcome at an early stage during the purchase process.

The Fiddler on the Roof is a metaphor in the story of Tevye the milkman with the fiddler in question in a precarious and uncertain position. It’s also a precarious position to take to assume that the annual tax on enveloped dwellings (ATED) and ATED-related stamp duty land tax (SDLT) work in identical ways as they derive from different parts of the tax code.

This article contains examples of scenarios involving joint purchase of a dwelling by a company...

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