Why there are three taxes
Stamp Duty Land Tax still applies in England and Northern Ireland and is collected by HMRC. Scotland replaced it with Land and Buildings Transaction Tax in April 2015, collected by Revenue Scotland. Wales replaced it with Land Transaction Tax in April 2018, collected by the Welsh Revenue Authority. The tax you pay is decided by where the property sits, not by where you live.
All three work in slices, all three charge more for additional property, and all three require a return shortly after completion. Beyond that the thresholds, the rates and the reliefs genuinely differ, and the differences have widened over the last few years rather than narrowed.
Standard residential rates compared
In England and Northern Ireland nothing is due up to £125,000, then 2% to £250,000, 5% to £925,000, 10% to £1.5 million and 12% above that.
In Scotland nothing is due up to £145,000, then 2% to £250,000, 5% to £325,000, 10% to £750,000 and 12% above that. The nil band is higher but the 10% rate arrives at £325,000 rather than £925,000, which makes Scotland markedly more expensive on family homes above about £400,000.
In Wales nothing is due up to £225,000, then 6% to £400,000, 7.5% to £750,000, 10% to £1.5 million and 12% above that. The starting threshold is the most generous in the United Kingdom, but the 6% rate that follows is steep.
The same purchase in each country
On a £310,000 home, an English or Northern Irish buyer pays £5,500, a Scottish buyer pays £5,100 and a Welsh buyer pays £5,100. The three are close at this level.
On a £600,000 home the picture changes. England and Northern Ireland charge £20,000. Scotland charges £33,350, because the 10% band has been running since £325,000. Wales charges £25,500. Scotland is now more than £13,000 dearer than England on the same house.
On a modest £200,000 home, England and Northern Ireland charge £1,500, Scotland charges £1,100 and Wales charges nothing at all, because the price sits below the Welsh threshold.
Additional property compared
England and Northern Ireland add 5 percentage points to every band, which works out as 5% of the whole price on top of the standard bill. Scotland charges the Additional Dwelling Supplement at a flat 8% of the entire price. Wales does not add a surcharge at all but applies a separate higher rate table starting at 5% and rising to 17%.
On a £310,000 second home that gives £21,000 in England and Northern Ireland, £29,900 in Scotland and £20,950 in Wales. Scotland is roughly £9,000 dearer on an identical purchase, which is a serious consideration for anyone building a portfolio across the border.
All three use a £40,000 entry threshold, and all three allow the extra charge to be reclaimed where you were replacing a main residence and sell the old home within the permitted window. That window is 3 years in England, Northern Ireland and Wales, and 3 years in Scotland as well following the extension from the original 18 months.
First time buyers
England and Northern Ireland give the most valuable relief, at nothing up to £300,000 and 5% from £300,001 to £500,000, worth up to £5,000 and lost entirely above £500,000. Scotland gives a smaller relief, raising the nil band from £145,000 to £175,000 and saving £600, but with no upper price limit. Wales gives no first time buyer relief at all, on the basis that its £225,000 threshold already does the job.
Commercial and non residential
England, Northern Ireland and Scotland all start charging non residential property at £150,000. England and Northern Ireland then charge 2% to £250,000 and 5% above. Scotland charges 1% to £250,000 and 5% above, so slightly cheaper in the middle. Wales starts at £225,000, charges 1% to £250,000, 5% to £1 million and 6% above £1 million, making it the only part of the United Kingdom with a rate above 5% on commercial property.
None of the three apply an additional property surcharge to non residential purchases, and none apply a flat corporate rate. The 17% flat charge on company purchases of dwellings above £500,000 is a feature of the English and Northern Irish system only. Scotland and Wales tax company purchases under their ordinary additional property rules instead.
Non resident buyers
England and Northern Ireland charge a further 2% where the buyer is not resident in the United Kingdom, on top of everything else. Scotland and Wales have no equivalent surcharge, so an overseas buyer purchasing in Edinburgh or Cardiff avoids that particular layer, though the Scottish supplement of 8% usually outweighs the saving.
Deadlines and filing
England and Northern Ireland require the return and the payment within 14 days of the effective date. Scotland and Wales both allow 30 days. Late filing penalties start at £100 in England and Northern Ireland, rising to £200 after 3 months and potentially to the full amount of the tax after 12 months. Revenue Scotland and the Welsh Revenue Authority operate their own penalty regimes on broadly similar lines.
If you own property in more than one part of the United Kingdom, remember that the surcharge tests look at properties worldwide. A flat in Glasgow counts when you buy in Manchester, and a house in Cardiff counts when you buy in Belfast, even though three different tax authorities are involved.
Buying across the border?
Three tax regimes, three sets of thresholds and three filing deadlines. We work out which rules apply, what the bill will be, and make sure the right return reaches the right authority on time.
Frequently asked questions
Is stamp duty different in Scotland?
Yes. Scotland charges Land and Buildings Transaction Tax instead. Nothing is due up to £145,000, and the 10% band starts at £325,000 rather than £925,000, so higher value homes cost considerably more than in England.
What is the stamp duty threshold in Wales?
£225,000, the highest in the United Kingdom. Above that Land Transaction Tax charges 6% up to £400,000. Wales has no first time buyer relief because the main threshold is already high.
Which part of the UK has the highest second home tax?
Scotland. The Additional Dwelling Supplement is a flat 8% of the whole purchase price, compared with an effective 5% in England and Northern Ireland.
Does Northern Ireland have its own stamp duty?
No. Northern Ireland uses Stamp Duty Land Tax on exactly the same basis as England, including the 5% additional property surcharge and the 2% non resident surcharge.
Do properties in other parts of the UK count for the surcharge?
Yes. All three regimes count properties owned anywhere in the world when deciding whether you own more than one dwelling, so a flat in Scotland affects a purchase in England and vice versa.