The number of homes worth more than £2 million that are held in corporate structures, which makes them liable to Annual Tax on Enveloped Dwellings (ATED), has fallen by 10 percent to 3,110 in the last year, according to HMRC’s latest statistics.

This is a significant drop from the 3,460 homes in 2015/16 and represents a fall in HMRC’s ATED receipts from £178 million to £175 million in 2016/17.

Private wealth law firm Boodle Hatfield believes high net worth individuals (HNWs) are increasingly taking their residential properties out of corporate structures so that ATED is no longer payable.

ATED was intro...