It is important to be aware that the ATED limit has been reduced from £2m to £1m with effect from April 2015 and to £500k from April 2016. The first valuation date is 31 March 2012, however properties need to be revalued every five years.
If you have residential property owned in a company, irrespective of where the company is resident or what use the property is put to, you will need to file an ATED return. The only manner by which to avoid the ATED charge is if the property is let commercially to an unconnected third party. The legislation is not yet clear if being available to let is enough to side step the liability.
I would strongly suggest if you have residential property held in corporate structures, you should look to formalise any arrangements that they have for letting the property or making it available so that there is contemporary evidence of intention.
For more information, please contact Tim Cook on firstname.lastname@example.org or by phone on 020 7724 6060.