Commentary

C2.1125 ATED-related gains and losses—overview

Capital gains tax
Capital gains tax | Commentary

C2.1125 ATED-related gains and losses—overview

Capital gains tax | Commentary

ATED-related gains and losses

C2.1125 ATED-related gains and losses—overview

The rules in C2.1125–C2.1129A apply to disposals made prior to 6 April 2019. For disposals made on or after 6 April 2019, see C2.1139–C2.1173. Transitional rules apply to unused losses existing at 6 April 2019 that have accrued on disposals made prior to that date. See C2.1142 for further details.

Finance Act 2013 introduced a capital gains tax charge on the disposal of certain types of high value UK residential property. In order for the disposal to be within the scope of the CGT charge, the annual tax on enveloped dwellings (ATED) charge (see Division B6.7) must have been payable during the period of ownership. The ATED-related CGT charge can therefore only be understood in the context of the ATED legislation. This is because it is first necessary to understand if ATED is payable during the ownership period before consideration of what part of the gain or loss on the sale is ATED-related. A number of

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