Taxation of the elite and super-elite of the UK property owned by legal entities.
The whole world is in the midst of the economic crisis began to struggle with offshore companies. The UK is no exception. Given the fact that the UK is the largest center of investment and capital inflows from around the world, before the UK government faces a difficult task – where to find the optimal combination of tax exemptions, and the maximum possible value of the inflow of taxes to the state budget to the pace investments in UK property is not reduced.
First, the UK government is interested in luxury and super luxury property. To 01 APR 2013 was a law, under which all the residential properties worth more £2 million in the case of the acquisition of its legal entity (no matter where registered Legal entity in the UK or offshore, or any other country) – were subject to Stamp duty at the rate of 15%. A private person when purchasing a property worth £2 million pay Stamp duty at 7% .
Rates of Stamp duty have remained unchanged, but from 01.04.2013 year was enacted a law that imposes an additional burden on legal persons, regardless of their jurisdiction who own a home from as little as £2 million of residential property in the UK. Such legal entity must pay an annual fee, which is calculated as a percentage of the property value – i.e. it’s a tax on ownership of residential property by legal entities. It’s called – Annual Tax on Enveloped Dwellings.
To the company has any obligation to pay Annual Tax on Enveloped Dwellings (ATED), to perform all the four conditions listed below:
· Property must be residential.
· Property must be located in the territory of the United Kingdom.
· The cost of real estate should be more expensive than £2 million as on 01.04.2012 or, if acquired later.
· The owner of the property must be a legal entity – a company or partnership in which at least one of the partners is a company or mutual Fund or investment company.
The amount of ATED is fixed and proportional to the value of real estate :
|
£2,000,001 – £5,000,000 |
£15,000 |
|
£5,000,001 – £10,000,000 |
£35,000 |
|
£10,000,001 – £20,000,000 |
£70,000 |
|
£20,000,001 and more |
£140,000 |
If the owner owns real estate not the entire year, then the amount of the annual fee shall be calculated in proportion to the part of the year when the property was owned.
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