How we saved a Chelsea property owner £31,000 on de-enveloping
Client X held a Chelsea flat worth around £1.8 million inside a company structure set up years earlier for privacy. The structure was costing money it no longer justified - annual ATED charges, Corporation Tax on deemed income, and accounting costs - while the original privacy rationale had fallen away after beneficial ownership registers came in.
We modelled de-enveloping (extracting the property from the company into personal ownership). We worked through the ATED position, the CGT on the company's disposal of the property to the shareholder, the SDLT on the transfer, and the eventual savings from no longer paying annual ATED and company running costs. We timed the de-enveloping to use available reliefs and structured it to minimise the immediate tax cost.