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Not a property developer for ATED

A company was held not to be a property developer for the purposes of annual tax on enveloped dwellings (ATED). Property developers enjoy relief from the tax under Finance Act 2013 s138(1).

A company acquired a residential property which it eventually improved and offered for sale.

On the facts of the case, the company was not running a property development trade. It was simply selling an investment property.

The case considered the badges of trade.

The case report can be downloaded from here.

Hopscotch Ltd [2019] TC 7127 [19.05]