Commentary

B6.709 ATED—taxable value

Business tax
Business tax | Commentary

B6.709 ATED—taxable value

Business tax | Commentary

B6.709 ATED—taxable value

The taxable value of an SDI is equal to its market value on the latest of the following valuation dates1:

  1.  

    •     date of acquisition

  2.  

    •     1 April 2012

  3.  

    •     1 April every 5 years after 1 April 2012 (ie 1 April 2017, 1 April 2022 and so on)

  4.  

    •     the date of a substantial acquisition or part disposal of an interest in an existing SDI (see below)

  5.  

    •     in the case of newly built or converted property, when it is completed or, if earlier, when it is first occupied, see B6.740–B6.743

The five-yearly valuation dates (ie 1 April 2012, 1 April 2017 and so on) apply to the next five chargeable periods beginning the following 1 April (eg the 1 April 2017 valuation date applies to the next five chargeable periods beginning 1 April 2018)2. This provision was added to correct an anomaly which meant that a chargeable person who has an interest that falls within ATED because of its value on 1 April 2017 would have to value their property on 1 April 2017 and file their return by 30 April 2017. Following this amendment, it was not be necessary to file a return until the chargeable period beginning 1 April 2018.

HMRC confirm that the valuation must be a specific price — an 'in the range of' value is not acceptable3. If an SDI value falls within 10% of a relevant ATED banding (for example, in relation to the £500,000 band, the SDI value was in the

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