Taxation of Chargeable Gains Act 1992 Schedule 4ZZA paragraph 7

Adjustments of ATED chargeable days

Schedule 4ZZA paragraph 7 deals with adjustments to the number of ATED (Annual Tax on Enveloped Dwellings) chargeable days used in calculating ATED-related capital gains, following amendments introduced by Finance Act 2019.

• Where the number of ATED chargeable days within a period of ownership needs to be recalculated, adjustments must be made to reflect the correct position.
• Changes may arise because of amendments to ATED returns, discovery assessments, or other corrections to the underlying ATED liability.
• Any adjustment to ATED chargeable days can affect the proportion of a chargeable gain that falls within the ATED-related capital gains tax regime rather than the standard CGT regime.
• The Finance Act 2019 amendments updated these adjustment provisions as part of wider reforms to the interaction between ATED and capital gains tax on high-value residential properties held by companies and other non-natural persons.