ATED Valuation Date: The Section 102 Multi-Layered Architecture (Crown Dates, Substantial Acquisitions, Partnership and CIS Variants, and the FA 2015 On-Ramp)

The single most common simplification on ATED valuation is that the most recent 5-yearly Crown date (1 April 2012, 2017, 2022, 2027, 2032) is the operative valuation date for the dwelling. That simplification is wrong in three different ways at once, and the costs of getting it wrong can be substantial. The right framework is multi-layered. FA 2013 s.102 sets out a taxable-value rule (the market value at the end of the latest day that falls on or before the chargeable day and qualifies as a valuation date) and then catalogues which days qualify: the standard 5-yearly Crown dates, but also the effective dates of substantial acquisitions and partial disposals, and (for partnership-held dwellings) the date an interest becomes a partnership asset or the effective date of a partial disposal for partnership purposes, and (for collective investment schemes) parallel CIS triggers. The operative valuation date for any given chargeable day is whichever of those qualifying dates is latest, on or before the day in question. Crown dates are a floor, not a ceiling.

Layered over that architecture is a separate temporal nuance: FA 2013 s.102(2A), inserted by FA 2015, provides that the 5-yearly Crown date is treated as if it were not a valuation date for the chargeable period beginning with that date. So the 1 April 2027 revaluation does not operate for the 2027/28 chargeable period (1 April 2027 to 31 March 2028); the 2027/28 return uses the prior valuation date (1 April 2022 for properties held since then, or any intervening valuation event under s.102). The 1 April 2027 valuation first bites the 2028/29 chargeable period (return filed by 30 April 2028). Practitioner pages and even some adviser communications routinely state that the 1 April 2027 valuation affects the 2027/28 return. That is wrong on the face of the statute.

And below the 5-yearly cycle, FA 2013 s.103 establishes a £40,000 chargeable-consideration threshold for substantial acquisitions and partial disposals. Acquisitions below £40,000 do not create fresh valuation dates standing alone; but s.103 also carries linked-transaction rules between connected parties, so a sequence of small connected-party top-ups can be aggregated to clear the £40,000 floor and create a deemed fresh valuation date. Partnership-held dwellings and CIS-held dwellings follow their own s.102 variant architectures rather than the non-partnership-company route. Each of these layers is well-established statute, but each is routinely missed in practitioner-facing summaries.

This page walks the architecture in five worked examples (the operative-valuation-date decision tree, the FA 2015 on-ramp clause walked end-to-end against a 2027/28 versus 2028/29 contrast, the £40,000 aggregation rule, the partnership variant, and the valuation-to-band-to-daily-amount chain) followed by 14 FAQs. For the event-focused 2027 revaluation deep-dive (acquisition-value treatment, transitional anti-avoidance, RICS evidence for the cycle itself), see our 2027 revaluation page. For the band table and worked examples, see our rates and bands table page and our ATED rates page. For mixed-use apportionment, see our mixed-use apportionment page.

The s.102 operative-valuation-date decision tree

The first concrete artefact on this page is the decision tree itself. Walk it in this order before any ATED return.

1. Identify the chargeable day. Typically 1 April at the start of the chargeable period for which you are filing the return. The chargeable period runs 1 April to 31 March; the operative valuation drives the band for that whole period.
2. List all candidate valuation dates for the dwelling. Include each 5-yearly Crown date (1 April 2012, 2017, 2022, 2027, 2032) that falls on or before the chargeable day. Include the effective date of any substantial acquisition or partial disposal (£40,000 or more in chargeable consideration under FA 2013 s.103). For partnership interests, include the effective date on which an interest became a partnership asset, and the effective date of any partial disposal made for partnership purposes (s.102 partnership variant). For CIS-held interests, include the effective date of any substantial acquisition or partial disposal made for scheme purposes (s.102 CIS variant).
3. Apply the FA 2015 s.102(2A) on-ramp filter. If the chargeable day falls in a chargeable period that begins on a 5-yearly Crown date, remove that Crown date from the candidate list for that period. Example: the chargeable day 1 April 2027 falls in the 2027/28 period, which begins on 1 April 2027, so the 1 April 2027 Crown date is removed.
4. Pick the latest remaining candidate that falls on or before the chargeable day. That is the operative valuation date under s.102. For most dwellings in 2026/27 (a normal mid-cycle year with no intervening events) the operative date is 1 April 2022. For dwellings with a £40,000-or-greater acquisition or partial disposal since 1 April 2022, the operative date is the event date. For partnership-held dwellings with a partnership variant event since 1 April 2022, the operative date is the event date.
5. Obtain the taxable value at the operative valuation date. RICS Red Book formal valuation is the gold standard. For clearly-in-band dwellings, informal evidence (estate agent appraisal, comparable sales) is accepted. For borderline-band dwellings (within 10 per cent of a £500k, £1m, £2m, £5m, £10m, or £20m boundary), commission an RICS Red Book valuation and consider the Pre-Return Banding Check route described below.
6. Match the taxable value to the band table. The 2026/27 bands are £500,001 to £1m (band 1), £1m to £2m (band 2), £2m to £5m (band 3), £5m to £10m (band 4), £10m to £20m (band 5), over £20m (band 6). 2026/27 annual chargeable amounts (per the Treasury Order indexation under s.101): band 1 £4,800, band 2 £9,800, band 3 £32,900, band 4 £77,150, band 5 £154,750, band 6 £309,950. Verify the current Treasury Order indexed figures at filing time against gov.uk.
7. Apply the s.99 annual chargeable amount and the s.105 daily-amount and adjusted-chargeable-amount mechanics. The annual amount is divided by the number of days in the period to produce a daily amount; the adjusted chargeable amount is the sum of daily amounts for the days the chargeable person is within the charge. Where the dwelling is held throughout the period, the annual and adjusted amounts coincide. Where a substantial acquisition or partial disposal mid-period creates a fresh valuation date partway through the period, the adjusted amount is the sum of pre-event and post-event daily amounts under the respective band charges.
8. Apply any reliefs. FA 2013 ss.133 to 150 reliefs are claimed on the return. Where a relief covers the whole period, the chargeable amount reduces to nil and the return is a claim-only return. The valuation-date discipline still matters because the band determines the gross figure that the relief is set against, and the audit trail supports the relief claim under any later enquiry.

Example 2: Trevor Holdings and the FA 2015 s.102(2A) on-ramp walked

Trevor Holdings Limited (UK ltd-co; holds a £3.6m London town house acquired May 2018; no substantial acquisitions or disposals since). The question is straightforward: for the 2027/28 chargeable period (1 April 2027 to 31 March 2028), what is the operative valuation date under s.102?

Candidate valuation dates for the dwelling:

1. 1 April 2017 (Crown date): pre-dates 2027/28 period, candidate.
2. 1 April 2022 (Crown date): pre-dates 2027/28 period, candidate.
3. 1 April 2027 (Crown date): pre-dates the 2027/28 chargeable days, candidate, subject to the s.102(2A) filter below.
4. May 2018 acquisition (substantial, £3.6m consideration): pre-dates 2027/28 period, candidate.

Apply s.102(2A). The 2027/28 chargeable period begins on 1 April 2027. Per s.102(2A), the 1 April 2027 Crown date is treated as not being a valuation date for the chargeable period beginning on it. Remove the 1 April 2027 Crown date from the candidate list for 2027/28.

Pick the latest remaining candidate. The remaining candidates are 1 April 2017, 1 April 2022, and the May 2018 acquisition. The latest is 1 April 2022 (Crown date). The operative valuation date for Trevor's 2027/28 return is 1 April 2022. Trevor uses the 1 April 2022 RICS valuation (assume that valuation was £3.4m) to produce a band 3 (£2m to £5m) banding, and the 2027/28 annual chargeable amount for band 3 per the Treasury Order indexed figures.

Contrast against the 2028/29 chargeable period. The 2028/29 period begins on 1 April 2028. The 1 April 2027 Crown date does not fall on the start of the 2028/29 period, so the s.102(2A) filter does not remove it. Candidates: 1 April 2017, 1 April 2022, 1 April 2027 (no longer filtered), and the May 2018 acquisition. The latest is 1 April 2027 (Crown date). The operative valuation date for Trevor's 2028/29 return is 1 April 2027. Trevor must commission a 1 April 2027 RICS valuation for use in the 2028/29 return (filed by 30 April 2028).

If the 1 April 2027 valuation surfaces £4.1m (a plausible London appreciation), Trevor stays in band 3 (£2m to £5m). If the 2027 valuation surfaces £5.2m, Trevor escalates to band 4 (£5m to £10m), with a step-change in the annual chargeable amount of more than £40,000 per period. The 1 April 2027 RICS valuation has the largest tax-cost impact in the cycle and is for the 2028/29 return, not the 2027/28 return. Practitioners who tell clients to commission the 2027 valuation for the 2027/28 return have either misread s.102(2A) or are propagating an SA-analogue framing borrowed from self-assessment, neither of which controls the ATED architecture.

Example 3: Olivetti Holdings and the £40,000 aggregation trigger

Olivetti Holdings Limited (UK ltd-co; acquired a £1.8m London flat in February 2020). In November 2024 Olivetti makes a £30,000 partial-interest top-up acquisition between connected parties (acquiring a 2 per cent additional interest from a related family company). In March 2026 Olivetti makes a further £15,000 partial-interest top-up between the same connected parties. The question is whether either of these top-ups creates a fresh valuation date under s.102.

The s.103 substantial-acquisition test runs as follows. The November 2024 £30,000 acquisition is below the £40,000 threshold, so standing alone it is not a substantial acquisition and does not create a fresh valuation date. The March 2026 £15,000 acquisition is below the £40,000 threshold standing alone. Both pass the standalone test.

The linked-transaction connected-party rule in s.103 then applies. The two acquisitions are between the same connected parties; £30,000 plus £15,000 equals £45,000, which exceeds the £40,000 threshold. The s.103 linked-transaction architecture aggregates the transactions and treats them as a single substantial acquisition. The effective date for the aggregated event is (broadly) the later of the two events, so March 2026.

Practical result. If HMRC applies the linked-transaction aggregation, March 2026 becomes a fresh valuation date for Olivetti's dwelling. For the 2026/27 chargeable period, the operative valuation date is now March 2026 (the later event), not 1 April 2022 (the prior Crown date).

Tax consequence. Suppose the 1 April 2022 valuation was £1.85m (band 2, £1m to £2m, 2026/27 annual chargeable amount £9,800), and the March 2026 valuation on the back of London appreciation is £2.1m (band 3, £2m to £5m, 2026/27 annual chargeable amount £32,900). The differential is £23,100 of additional ATED in 2026/27 and onwards until the next valuation event. Olivetti's tax bill more than triples on a connected-party transaction sequence that on its face looked too small to engage ATED valuation mechanics at all.

Operational lesson. Sub-£40,000 connected-party top-ups can aggregate into a substantial acquisition and trigger a fresh (often unfavourable) valuation date. Where partial-interest activity between connected parties is contemplated, run the s.103 linked-transaction analysis before the second transaction completes. The right answer is often to defer (cumulative consideration remains below £40,000 over time), to structure differently (using third-party arm's length acquirers where commercial), or to accept the fresh valuation date prospectively and plan around it.

Example 4: Saffron Estates Partnership and the s.102 partnership variant

Saffron Estates Partnership LLP (UK partnership with a corporate member; owns a £2.3m London flat; acquired 2019). In June 2025 the partnership admits a new corporate partner (Saffron Holdings B Limited), which contributes capital and acquires an interest in the partnership. The question is whether this admission triggers a fresh valuation date for ATED purposes.

FA 2013 s.102 partnership variant analysis. The dwelling is a partnership asset. The s.102 partnership variant identifies as valuation dates the effective date on which an interest in the dwelling becomes a partnership asset and the effective date of any partial disposal of an interest made for partnership purposes.

The June 2025 admission is not a fresh "interest becoming a partnership asset" because the dwelling was already a partnership asset before June 2025; nothing new became a partnership asset in June 2025. However, the admission may constitute a partial disposal made for partnership purposes. Existing partners' beneficial interests in partnership assets are diluted by the admission of the new partner. Whether that dilution is properly characterised as a partial disposal for partnership purposes is a question of partnership-tax and general-tax analysis, and the answer depends on the partnership deed mechanics, the contributed capital, the partnership's profit and loss sharing ratios, and the partnership-tax treatment of the dilution under TCGA 1992.

Provisional result (subject to specialist legal analysis). June 2025 may be a fresh valuation date under the s.102 partnership variant. For the 2025/26 chargeable period, the operative valuation date for Saffron's dwelling may be June 2025 (post-admission), not 1 April 2022 (the prior Crown date).

Tax consequence. If the dwelling is revalued as at June 2025 (assume £2.4m on appreciation), the band shifts from band 2 (£1m to £2m, on the 1 April 2022 £1.95m valuation) to band 3 (£2m to £5m). 2025/26 annual chargeable amount moves from £9,500 (band 2) to £31,300 (band 3) on the Treasury Order indexed figures applicable to 2025/26. The differential is £21,800.

Operational lesson. Partnership admissions, retirements, and capital changes can trigger fresh valuation events under the s.102 partnership variant that are easily missed by advisers applying the non-partnership-company framework. Where any partnership-structure change touches an ATED-relevant dwelling, engage specialist partnership-tax counsel to walk both the partnership-tax characterisation and the s.102 valuation-date consequence. The same logic applies to CIS structures under the s.102 CIS variant.

Example 5: the valuation-to-band-to-daily-amount chain walked end-to-end

Trevor Holdings Limited (the dwelling from Example 2). For the 2026/27 chargeable period (1 April 2026 to 31 March 2027), the operative valuation date is 1 April 2022 (no s.102(2A) issue this period; no substantial-acquisition events since 2022). The 1 April 2022 RICS valuation was £3.4m.

Step by step:

1. Operative valuation date: 1 April 2022.
2. Taxable value at the operative valuation date: £3.4m.
3. Band match: band 3 (£2m to £5m).
4. 2026/27 annual chargeable amount per s.99 indexed under s.101: £32,900 (Treasury Order indexed figure for 2026/27; verify at filing time against gov.uk).
5. Days in the 2026/27 chargeable period: 365 (1 April 2026 to 31 March 2027).
6. Daily amount per s.105: £32,900 divided by 365, approximately £90.14 per day.
7. Days Trevor is within the charge: assume Trevor owns throughout, so 365 days.
8. Adjusted chargeable amount per s.105: £90.14 times 365, approximately £32,900 (the full annual charge).
9. Reliefs: none (Trevor's flat is family-occupied, so no s.133 rental relief or other relief is available).
10. Return mechanics: ATED return due 30 April 2026; payment due same day.

Variation 1: mid-year disposal. Suppose Trevor sells the flat on 30 September 2026 (mid-period). Days within charge: 1 April 2026 to 30 September 2026, 183 days. Adjusted chargeable amount: £90.14 times 183, approximately £16,496. The return mechanics shift to an adjusted-chargeable-amount return under Schedule 33; any pro-rated refund of post-disposal charge is claimable via amendment under Schedule 33 paragraph 3 within the period-boundary window.

Variation 2: mid-year band-up via substantial acquisition. Suppose a substantial acquisition (an £800,000 extension to the property purchased from a connected party) occurs on 1 October 2026 (mid-period), pushing the valuation from £3.4m (band 3) to £5.6m (band 4). For 1 April 2026 to 30 September 2026 (183 days): band 3, £32,900 annual, £90.14 per day, £16,496 adjusted. For 1 October 2026 to 31 March 2027 (182 days): band 4 (£5m to £10m), 2026/27 annual chargeable amount £77,150 per the indexed table, £211.37 per day, £38,469 adjusted. Total 2026/27 adjusted chargeable amount: £16,496 plus £38,469, approximately £54,965. The post-October operative valuation date is 1 October 2026 (the substantial-acquisition effective date).

The Pre-Return Banding Check (PRBC) for borderline dwellings

HMRC's published Pre-Return Banding Check is the operational lever for dwellings whose taxable value sits within 10 per cent of a band boundary at the operative valuation date. Eligibility is on either side of the boundary, so a £1.92m flat (8 per cent below the £2m boundary) is just as eligible as a £2.05m flat (2.5 per cent above). The submission is at no cost to the chargeable person; HMRC processes the PRBC on a non-binding basis and provides a view of the band. The PRBC view is not binding on HMRC at return-filing or under subsequent enquiry, but in practice the view holds for a return that follows it provided the underlying RICS evidence remains current.

The PRBC is submitted before the 30 April return deadline, typically in February or early March of the year of filing. Submit with a contemporaneous RICS Red Book valuation, the operative-valuation-date analysis (showing the latest qualifying date under the s.102 decision tree), and any relevant context (recent comparable sales, condition issues, partial-interest structure). HMRC responds within a few weeks. Where the PRBC confirms band 1 versus band 2 (or band 2 versus band 3 on borderline cases), the tax-cost differential per chargeable period is in the four to six figures. The PRBC is one of the highest-leverage no-cost compliance tools in the ATED architecture and is materially under-used by overseas-corporate filers.

Mixed-use apportionment and the s.102 valuation

FA 2013 s.117 governs mixed-use property apportionment for ATED. Where a dwelling is part of a mixed-use property (a flat over a shop, an upper-floor flat in a building with ground-floor commercial use, a town house with a converted lower-ground commercial unit), ATED applies only to the residential element where that residential element is worth more than £500,000. Apportionment between the residential and commercial elements is on a just-and-reasonable basis. There is no statutory formula. HMRC accepts floor-area-based apportionment and value-based apportionment, and in some cases income-based apportionment where the property is commercially rented.

The residential-element value drives the s.102 valuation cycle for the apportioned interest. The operative valuation date applies to the residential element, and the band table is read off the residential-element value (not the whole property value). A £1.4m mixed-use property with a £900,000 residential element (apportioned on a floor-area basis) is a band 1 ATED dwelling, not a band 2. Engage a RICS Red Book valuer who can document the residential element separately and provide contemporaneous evidence of the apportionment methodology. Retain that evidence with the return file in case of HMRC enquiry on the apportionment basis.

How this page differs from the event-focused sibling

The event-focused sibling page ated-valuation-date-rules-2027-revaluation walks the 2027 revaluation specifically: the acquisition-value treatment for dwellings bought between Crown dates, the transitional anti-avoidance, the RICS evidence cycle for the revaluation itself, and the PRBC mechanism in the context of the 2027 cycle. That page assumes the reader knows the 2027 cycle is the topic. This page covers the architectural framework that contains the 2027 cycle as one (important) layer, with explicit refusal of the "most recent Crown date is always operative" simplification, full coverage of the s.102(2A) on-ramp clause, the £40,000 aggregation rule, the partnership and CIS variants, and the valuation-to-band-to-daily-amount chain. Read this page first if you are orienting to the architecture; read the sibling page for the 2027 event detail.

For amendments driven by re-banding (PRBC reveals the band was wrong, the s.102 analysis surfaces an earlier missed valuation event), see our ATED amendment guide. For the broader ATED regime context, see our ATED rates page and our avoiding common ATED mistakes page.

Frequently asked questions

The FAQ list above covers the operative valuation date for 2026/27 (FAQ 1), the s.102(2A) on-ramp affecting the 2027 revaluation (FAQ 2 and FAQ 13), commissioning the 2027 RICS valuation (FAQ 3), the £40,000 aggregation rule on connected-party top-ups (FAQ 4), the PRBC mechanism (FAQ 5), the valuation-to-bill calculation chain (FAQ 6), mixed-use apportionment (FAQ 7), the partnership variant under new-partner admission (FAQ 8), the impact of downward valuation movement (FAQ 9), mid-cycle appreciation (FAQ 10), the difference between substantial acquisition and partial disposal (FAQ 11), documentation discipline for HMRC enquiry resilience (FAQ 12), and evidence standards (FAQ 14).

Next step

If you hold one or more ATED-relevant dwellings, the operative valuation date for the current chargeable period is the latest day on or before the chargeable day that qualifies under FA 2013 s.102, after applying the s.102(2A) on-ramp filter to remove the 5-yearly Crown date for the period beginning on it. Substantial acquisitions and partial disposals of £40,000 or more (or aggregated connected-party sequences clearing the threshold) create fresh valuation dates; partnership admissions and CIS events follow the s.102 variant architectures. The 2027 valuation cycle bites the 2028/29 return, not the 2027/28 return. Contact us via the form below to discuss the s.102 analysis for any dwelling in your portfolio before the next return deadline.