It is that time of year again when we like to draw your attention to the need to prepare and submit your Annual Tax on Enveloped Dwellings (ATED) Returns.

By 30 April 2017, you must have completed your ATED Return and made your ATED payment for the period 1 April 2017 through to 31 March 2018.

There may well be a change of circumstances, which is relevant for consideration in the ATED Return, such as the letting of a residential property. If this is the case, then early consideration and preparation of the ATED Return is advisable.

There are also several reasons why you may want to consider possible restructuring options for your UK residential property holdings:

• Sweeping changes are being introduced for UK non-domiciles from 6 April 2017 which will remove the UK inheritance tax benefit of holding in a corporate structure. (See our alert on this, titled “Non-Domicile Changes in the United Kingdom From April 2017 – Are You Ready?”)

• Properties will need to be revalued as at 1 April 2017 (for the ATED period from 1 April 2018), which could well result, particularly for borderline cases, in properties moving to a more expensive ATED tax bracket from 1 April 2018. Restructuring in anticipation of these changes may be advisable.

We look forward to receiving your instructions for the preparation of your ATED Return.

Furthermore, if you wish to consider restructuring, we would be delighted to assist with this.