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The annual tax on enveloped dwellings (ATED) was introduced in Finance Act 2013 (FA 2013) as part of a package of measures aimed at making it less attractive to hold high-value UK residential property indirectly, eg through a company, in order to avoid or minimise taxes such as stamp duty land tax (SDLT) on a subsequent disposal of the property. For more details on ATED, see Practice Note: ATED—the basics.
As part of this package of measures, FA 2013 introduced an extension to the capital gains tax (CGT) regime by introducing a CGT charge on disposals on or after 6 April 2013 of property interests falling within the scope of ATED by both resident and non-resident non-natural persons (NNPs). This Practice Note summarises the CGT charge on ATED-related gains (referred to as the ATED CGT charge). With effect from 6 April 2019, the ATED CGT charge is abolished. From this date, most NNPs pay corporation tax on chargeable gains arising from immovable property. For more detail on this and rebasing for gains that would have been subject to the ATED CGT charge, see Practice Note: Non-residents and tax on chargeable gains from 6 April 2019—gains and UK immovable property.
The ATED CGT charge was enacted by FA 2013,
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ECHR, art 5(4)—rights and dutiesThe scope of article 5(4) Article 5(4) of the European Convention of Human Rights (ECHR) provides that: 'Everyone who is deprived of his liberty by arrest or detention shall be entitled to take proceedings by which the lawfulness of his detention shall be decided
Lexcel—assessmentLexcel is the Law Society's practice management standard. It is not compulsory although Lexcel accreditation can be helpful for firms wishing to be accredited under the Conveyancing Quality Scheme or the Legal Service Board's Specialist Quality Mark. This Practice Note tells you
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Qualified one-way costs shifting (QOCS)What is QOCS?Qualified one-way costs shifting (QOCS) was introduced on 1 April 2013 as part of the Jackson costs reforms following the removal of a claimant’s right to recover additional liabilities from the defendant, ie success fees and after the event (ATE)
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