Three Different Stamp Duty Regimes Across the UK

What most people call "Stamp Duty" is actually three separate taxes depending on where in the UK the property is. England and Northern Ireland still charge Stamp Duty Land Tax (SDLT) under HMRC. Scotland devolved the tax in 2015 and replaced it with the Land and Buildings Transaction Tax (LBTT), administered by Revenue Scotland. Wales followed in 2018 with the Land Transaction Tax (LTT), administered by the Welsh Revenue Authority. The rates, bands, reliefs and surcharges are all different — sometimes by a few hundred pounds, sometimes by tens of thousands on the same purchase.

First-time buyer relief

England's SDLT FTB relief is the most generous: 0% on the first £300,000 and 5% from £300,001 to £500,000, with a maximum saving of £8,750 on a purchase up to £500k. But it's withdrawn entirely at £500,001 and above — a real cliff edge that costs first-time buyers around £5,000 for crossing it by a single pound. Scotland takes a much more modest approach: just raising the LBTT nil-rate threshold from £145,000 to £175,000, capping the saving at £600 regardless of purchase price. Wales offers no specific first-time buyer relief — but the standard £225,000 nil-rate threshold means most starter homes in Wales escape LTT entirely without a special scheme.

Additional property surcharge — and the Scotland penalty

All three nations charge extra on second homes and buy-to-lets, but they do it differently. England (5%) and Wales (5%) add five percentage points to each band of the standard rates. Scotland's Additional Dwelling Supplement (ADS) is 8% applied to the full purchase price — not in bands. So a £400,000 additional property pays around £30,000 in England, £30,500 in Wales, but £45,350 in Scotland (£13,350 standard LBTT + £32,000 ADS). The £40,000 exemption applies in all three regimes — properties below that threshold escape the surcharge.

Filing deadlines

England/NI gives you just 14 days from completion to file the SDLT return with HMRC and pay. Scotland and Wales give 30 days from the effective date of the transaction. Your conveyancing solicitor normally handles the filing as part of completion, but late penalties bite quickly — £100 fixed for a missed deadline, then daily charges and interest on the unpaid tax.

Non-UK residents

Only England and Northern Ireland charge a non-UK resident surcharge (2%), introduced in April 2021. It applies on top of the standard rates and any additional-property surcharge — so a non-resident buying an extra English home pays standard SDLT plus the 5% surcharge plus the 2% non-resident surcharge. Scotland and Wales don't charge a separate non-resident rate.