ATED and ATED-related CGT apply to “non-natural persons” which includes companies, partnerships where one or more of the partners is a company, and collective investment vehicles. ... ATED and ATED-related CGT do not apply to a trust which holds property either directly, or through a nominee company.

What does ated apply?

Overview. ATED is an annual tax payable mainly by companies that own UK residential property valued at more than £500,000. was valued at more than: £2 million (for returns from 2013 to 2014 onwards)

Who is liable for ated?

All the partners are liable to pay the tax, not just the corporate member. Accordingly, ATED can even apply to individuals. However, no double taxation arises as only one amount of tax is levied with respect to each property subject to the charge (FA 2013, s. 104).