15 per cent rate of SDLT for high-value residential property transactions
15 per cent rate of SDLT for high-value residential property transactions

The following Tax guidance note provides comprehensive and up to date legal information covering:

  • 15 per cent rate of SDLT for high-value residential property transactions
  • When was the 15% rate introduced?
  • When does the 15% rate apply?
  • Are there any exclusions or reliefs?
  • In-force dates and transitional provisions

The higher rate of stamp duty land tax (SDLT) for high-value residential property (the 15% rate) was introduced as part of a package of measures aimed at making it less attractive to hold high-value UK residential property indirectly, eg through a company, in order to avoid or minimise taxes such as SDLT on a subsequent disposal of the property.

The other measures included in the anti-avoidance package relating to high-value UK residential property include:

  1. the annual tax on enveloped dwellings (ATED) which applies to high-value UK residential property owned on, or acquired after 1 April 2013, by non-natural persons (NNPs) (for further details, see Practice Note: ATED—the basics), and

  2. a capital gains tax (CGT) charge on sales of high-value UK residential property by NNPs (for further details, see Practice Note: Capital gains tax charge on ATED-related gains [Archived]) (this charge was abolished with effect from 6 April 2019 when non-UK residents became subject to CGT on their gains arising from UK immovable property, for more details see Practice Note: Non-residents and tax on chargeable gains from 6 April 2019—gains and UK immovable property)

For general background information about the applicable rates of SDLT, see Practice Note: Rates of SDLT.

SDLT ceased to apply to any land transaction involving any interests in or over land in Scotland from 1 April 2015. From that date,