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Official guidance
Capital Gains Manual

CG73600P · Land: Capital Gains Tax on assets subject to annual tax on enveloped dwellings (ATED): disposals from 6 April 2013 to 5 April 2019

  • CG73600 · Dwellings subject to ATED: introduction: Budget 2012
  • CG73601 · Dwellings subject to ATED: introduction: ATED - general outline
  • CG73602 · Dwellings subject to ATED: introduction: capital gains tax charge - general outline
  • CG73610 · Dwellings subject to ATED: main statutory provisions
  • CG73611 · Dwellings subject to ATED: persons chargeable under TCGA92/S2B
  • CG73612 · Dwellings subject to ATED: persons chargeable: individuals etc with ‘indirect’ interests in residential property
  • CG73616 · Dwellings subject to ATED: disposals chargeable under TCGA92/S2B
  • CG73617 · Dwellings subject to ATED: relevant high value disposal: condition A - chargeable interest
  • CG73618 · Dwellings subject to ATED: relevant high value disposal: condition B - single-dwelling interest
  • CG73619 · Dwellings subject to ATED: relevant high value disposal: condition C - ATED charge
  • CG73620 · Dwellings subject to ATED: relevant high value disposal: condition D - the threshold amount
  • CG73625 · Land: Capital gains tax (CGT) on assets subject to annual tax on enveloped dwellings (ATED): Dwellings subject to ATED: computation of gains and losses: general
  • CG73626 · Dwellings subject to ATED: computation of gains and losses: chargeable interests held on 5 April 2013
  • CG73628 · Dwellings subject to ATED: computation of gains and losses: chargeable interests held on 5 April of the relevant year - examples
  • CG73632 · Dwellings subject to ATED: computation of gains and losses: chargeable interests acquired after 5 April of the relevant year
  • CG73634 · Dwellings subject to ATED: computation of gains and losses: chargeable interests acquired after 5 April of the relevant year - examples
  • CG73638 · Dwellings subject to ATED: computation of gains and losses: chargeable interests held on 5 April of the relevant year: para 5 election applies
  • CG73640 · Dwellings subject to ATED: computation of gains and losses: chargeable interests held on 5 April of the relevant year: para 5 election applies - example
  • CG73642 · Dwellings subject to ATED: computation of gains and losses: Rule for certain disposals to which both ATED-related CGT and Non-Resident CGT relate
  • CG73643 · Dwellings subject to ATED: computation of gains and losses: Rule for certain disposals to which both ATED-related CGT and Non-Resident CGT relate – examples
  • CG73645 · Dwellings subject to ATED: how ATED-related gains/losses are charged/relieved - general
  • CG73650 · Dwellings subject to ATED: how ATED-related gains/losses are charged/relieved - marginal relief for gains
  • CG73655 · Dwellings subject to ATED: how ATED-related gains/losses are charged/relieved - restriction on losses
  • CG73660 · Dwellings subject to ATED: interaction with TCGA92/S161 (assets appropriated to trading stock)
  • CG73665 · Dwellings subject to ATED: interaction with TCGA92/S185 (exit charge on company leaving the UK)
  • CG73667 · Dwellings subject to ATED: interaction with wasting assets rules
  • CG73669 · Dwellings subject to ATED: interaction with capital allowances
  • CG73670 · Land: Capital gains tax (CGT) on assets subject to annual tax on enveloped dwellings (ATED): Dwellings subject to ATED: administration of capital gains tax (CGT) charge under TCGS92/S2B
  1. Land: Capital Gains Tax on assets subject to annual tax on enveloped dwellings (ATED): disposals from 6 April 2013 to 5 April 2019: contents
  2. Dwellings subject to ATED: computation of gains and losses: chargeable interests acquired after 5 April of the relevant year - examples

CG73634 | Dwellings subject to ATED: computation of gains and losses: chargeable interests acquired after 5 April of the relevant year - examples

From HM Revenue & Customs · Capital Gains Manual

1.Acquisition in April 2014 for £4,000,000

2.Acquisition in October 2015 for £1,500,000

1.Acquisition in April 2014 for £4,000,000

Basic information:

Residential property acquired April 2014 for £4,000,000 and disposed of April 2018 for £6,000,000.

Estimated Indexation factorYear
0.25April 2014 to April 2018
Total number of days chargeable to ATED730
Total days April 2014 to April 20181,460

Stage 1

Disposal proceedsAmount
-£6,000,000
Allowable deductions for CGT purposes£4,000,000
Gain on CGT rules£2,000,000

Stage 2

Days in period of ownership that are chargeable to ATED (CD) 730

Total days (TD) 1,460

CD/TD x gain on CGT rules ((730/1,460) x £2,000,000) = £1,000,000

ATED-related chargeable gain £1,000,000

Stage 3

Not required - gain under stage 2

Stage 4

Unadjusted gain from stage 1 above £2,000,000

Less

ATED related gain £1,000,000

Notional indexation (see below) £500,000 £1,500,000

£500,000

Non ATED-related gain £500,000

Notional indexation:

Maximum indexation (£4,000,000 x 0.25) = £1,000,000

Relevant fraction: ((TD - CD) / TD) x indexation

((1460 - 730) / 1460) x £1,000,000) = £500,000

2.Acquisition in October 2015 for £1,500,000

Basic information:

Residential property acquired October 2015 for £1,500,000 and disposed of April 2018 for £2,500,000.

Estimated Indexation factorYear
0.20October 2015 to April 2018
Total number of days chargeable to ATED730
Total days October 2015 to April 2018913

Stage 1

Disposal proceeds £2,500,000

Allowable deductions for CGT purposes £1,500,000

Gain on CGT rules £1,000,000

Stage 2

Days in period of ownership that are chargeable to ATED (CD) 730

Total days (TD) 913

CD/TD x gain on CGT rules ((730/913) x £1,000,000) = £799,562

ATED-related chargable gain £799,562

Stage 3

Not required – gain under stage 2

Stage 4

Unadjusted gain from stage 1 above £1,000,000

Less

ATED realated gain £799,562

Notional indexation (see below) £60,131 £859,693

£140,307

Non ATED-related gain £140,307

Notional indexation:

Maximum indexation (£1,500,000 x 0.20) = £300,000

Relevant fraction: ((TD – CD) / TD) x indexation

((913 – 730) / 913 x £300,000) = £60,131

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