The Renters’ Rights Act 2025 (RRA 2025) shakes up the traditional structure of residential tenancies – fixed-term assured shorthold tenancies will be abolished and home rentals must instead take place as assured periodic tenancies (APTs) from 1 May 2026.

One elusive but significant consequence of this arises from the interaction between the new tenancy model and the existing Stamp Duty Land Tax (SDLT) regime.

However, what looks like just a shift in tenancy structure could, in practice, pull thousands of renters into scope of SDLT reporting and payment obligations for the first time.

The Annual Tax on Enveloped Dwellings (‘ATED’) is a yearly tax mainly payable by non-natural persons (i.e. companies) that own UK residential property valued at over £500,000.

The government has issued the Annual Tax on Enveloped Dwellings (Indexation of Annual Chargeable Amounts) Order 2026 (SI 2026/156), which updates the annual ATED charges for periods beginning on or after 1 April 2026. The Order came into force on 24 February 2026 and fulfils the statutory requirement in s.101(5) Finance Act 2013 to uprate the annual charges in line with inflation.