Research and analysis

Views and behaviours in relation to the Annual Tax on Enveloped Dwellings

The report explores reasons for taxpayers’ behaviour regarding enveloped property and the impact of the Annual Tax on Enveloped Dwellings (ATED) on this behaviour.


Views and behaviours in relation to the Annual Tax on Enveloped Dwellings

This file may not be suitable for users of assistive technology. Request an accessible format.

If you use assistive technology (such as a screen reader) and need a version of this document in a more accessible format, please email Please tell us what format you need. It will help us if you say what assistive technology you use.


The Government has introduced an Annual Tax on Enveloped Dwellings (ATED) as one of a set of wider Stamp Duty Land Tax (SDLT) anti-avoidance measures. This research has filled a knowledge gap by providing qualitative evidence on why properties are held in corporate ‘envelopes’. It has also contributed towards assessing the impact of ATED and the likely behavioural response to future policy changes.

The research involved 40 in depth interviews with individuals who own enveloped properties, representatives of companies that own or manage property envelopes or their agents.

The qualitative research findings suggest that ATED has been successful in discouraging the initial enveloping of properties, with agents stating they would not advise enveloping to their clients in the future. However, it seems that where an envelope already exists few are de-enveloping their property as the ATED rate does not warrant losing the benefits of the envelope, such as Inheritance Tax (IHT) and privacy protection.

Published 17 September 2015