Guide · 9 min read
The three-nation stamp duty picture for landlords: SDLT with the 5% surcharge in England and NI, LBTT with 8% ADS in Scotland, LTT in Wales, plus the 6+ property and mixed-use routes.
Written by Matt Lenzie · Published 10 June 2026
Advice from
Matt Lenzie · 25+ year career banker (Bank of Scotland, Lloyds Banking Group). £300m+ raised for property clients.
25+ year career banker (Bank of Scotland, Lloyds Banking Group). £300m+ raised for property clients.
A landlord completing on a £300,000 single let in England in June 2026 hands HMRC £20,000 in Stamp Duty Land Tax (SDLT). An owner-occupier buying the same house pays £5,000. The £15,000 difference is the 5% additional dwelling surcharge, raised from 3% on 31 October 2024, and it applies to every band of the calculation, on every investment purchase, with no taper and no allowance. Buy the same property in Scotland and the bill is £28,600. In Wales it is £19,950. Three nations, three regimes, three very different numbers on an identical price.
This guide sets out all three regimes with full band tables, the company-specific rules including the 17% flat rate and ATED, and the two structural levers that still exist at portfolio scale after the abolition of Multiple Dwellings Relief: the 6+ dwellings rule and mixed-use classification. If you want the number for a specific purchase first, our buy-to-let stamp duty calculator handles all three nations and the company rates.
SDLT applies in England and Northern Ireland. For the 2025/26 tax year the residential bands run 0% to £125,000, 2% to £250,000, 5% to £925,000, 10% to £1,500,000 and 12% above. Anyone buying an additional dwelling, and any company buying any dwelling, adds the 5% surcharge to every band.
| Price band | Standard rate | Additional dwelling rate |
|---|---|---|
| £0 to £125,000 | 0% | 5% |
| £125,001 to £250,000 | 2% | 7% |
| £250,001 to £925,000 | 5% | 10% |
| £925,001 to £1,500,000 | 10% | 15% |
| Above £1,500,000 | 12% | 17% |
Worked example on a £300,000 buy-to-let, whether bought personally as a second property or through a limited company:
| Slice | Rate | SDLT |
|---|---|---|
| First £125,000 | 5% | £6,250 |
| £125,001 to £250,000 | 7% | £8,750 |
| £250,001 to £300,000 | 10% | £5,000 |
| Total | 6.7% effective | £20,000 |
The surcharge element is always exactly 5% of the full purchase price, £15,000 here, sitting on top of whatever the standard computation produces. That makes the marginal arithmetic easy at the desk: every additional £100,000 of purchase price in the 5% standard band costs a landlord £10,000 in SDLT.
Scotland charges Land and Buildings Transaction Tax (LBTT), administered by Revenue Scotland. The structural difference is the Additional Dwelling Supplement (ADS). Unlike the SDLT surcharge, which loads each band, the ADS is a flat 8% of the entire purchase price on any additional dwelling or company purchase of £40,000 or more, raised from 6% on 5 December 2024.
| Price band | LBTT rate | With 8% ADS |
|---|---|---|
| £0 to £145,000 | 0% | 8% |
| £145,001 to £250,000 | 2% | 10% |
| £250,001 to £325,000 | 5% | 13% |
| £325,001 to £750,000 | 10% | 18% |
| Above £750,000 | 12% | 20% |
The same £300,000 purchase in Scotland: LBTT of £4,600 (£0 + £2,100 + £2,500) plus ADS of £24,000, a total of £28,600, which is 9.5% of the price and £8,600 more than England. Scottish yields are often strong enough to absorb that, but the ADS is the single biggest reason cross-border portfolio buyers model Scottish acquisitions separately rather than assuming English numbers travel north.
Wales charges Land Transaction Tax (LTT), administered by the Welsh Revenue Authority. Landlords and companies pay the higher residential rates, which since December 2024 sit roughly four to five percentage points above the main rates and start at 5% from the first pound.
| Price band | Higher residential rate |
|---|---|
| £0 to £180,000 | 5% |
| £180,001 to £250,000 | 8.5% |
| £250,001 to £400,000 | 10% |
| £400,001 to £750,000 | 12.5% |
| £750,001 to £1,500,000 | 15% |
| Above £1,500,000 | 17% |
The £300,000 purchase in Wales: £9,000 on the first £180,000, £5,950 on the next £70,000, £5,000 on the final £50,000, a total of £19,950. Marginally cheaper than England at this price point, materially cheaper than Scotland.
A limited company never gets the standard residential rates. The surcharge applies to a company's first purchase and every purchase after it, in all three nations. Incorporated landlords price that in from day one as part of the limited company buy-to-let decision, and the same surcharged rates apply when an existing personal portfolio is moved into a company, the cost worked through in our guide to transferring property to a limited company. There is also a second company-specific regime that catches people: the flat 17% SDLT rate.
Where a company (or other non-natural person) buys a single dwelling for more than £500,000 in England or Northern Ireland, the default charge is a flat 17% of the whole price, £85,000 minimum, rather than the banded computation. The rate was 15% until 31 October 2024. The let-out is relief for qualifying property rental businesses: a company buying a £600,000 dwelling to let on a commercial basis to unconnected tenants claims the relief and pays the banded surcharged rates (£47,500 on £600,000) instead of the flat £102,000.
Claiming that relief has a tail. The property enters the Annual Tax on Enveloped Dwellings (ATED) regime, under which company-held dwellings valued above £500,000 attract an annual charge, £4,450 for the £500,000 to £1,000,000 band and £9,150 for the £1,000,000 to £2,000,000 band in the 2025/26 chargeable period per HMRC. A genuine rental business claims the ATED rental relief and pays nothing, but the relief must be claimed on an annual ATED return. Miss the return and penalties accrue even though no tax was due. If the dwelling is ever occupied by a connected person, a director or their family, both the ATED relief and the 17%-rate relief are lost retrospectively. This is the trap: the reliefs are generous, but they are conditional on use, not on intention at purchase.
Since Multiple Dwellings Relief (MDR) was abolished for transactions completing on or after 1 June 2024, the 6+ dwellings rule is the main remaining structural relief in England and Northern Ireland. Where six or more dwellings are acquired in a single transaction, the buyer may elect to treat the purchase as non-residential and apply the commercial rates: 0% to £150,000, 2% to £250,000 and 5% on everything above, with no surcharge, because the surcharge is a residential-rates concept.
Six flats bought as one block for £1,500,000:
| Computation | Workings | SDLT |
|---|---|---|
| Surcharged residential rates | £6,250 + £8,750 + £67,500 + £86,250 | £168,750 |
| Non-residential rates (6+ election) | £0 + £2,000 + £62,500 | £64,500 |
| Saving | 11.25% vs 4.3% effective | £104,250 |
The election is available to companies as well as individuals, which makes it central to how block acquisitions are structured. It also interacts with the financing: a six-flat block on one freehold title is a multi-unit freehold block for mortgage purposes, funded on a single facility, and the duty saving frequently covers most of the deposit gap between a 75% and an 80% loan. Note the mechanics matter: the six dwellings must pass in a single transaction or as linked transactions. Six separate completions with six separate contracts on six unconnected purchases are six residential computations.
What replaced MDR planning? Before June 2024, a buyer of two to five units averaged the price per dwelling and often reached a lower band. That route is gone. As of June 2026 the planning conversation at the desk has collapsed to three questions: can the deal be assembled to six or more dwellings in one transaction, does any element make the property genuinely mixed-use, and if neither, is the entity and timing right. Scotland and Wales kept their own versions of multiple dwellings relief within LBTT and LTT, so a four-unit purchase that gets no relief in Manchester may get one in Glasgow.
A property that is genuinely part-residential and part-commercial, the classic flat above a shop, a pub with owner's accommodation, a yard with a cottage and commercial workshops, is charged entirely at non-residential rates. No surcharge, 5% top rate. On a £400,000 shop-plus-flat the duty is £9,500, against £30,000 if the same £400,000 bought a pure dwelling with the surcharge. The lending side mirrors the tax side: these assets sit in semi-commercial mortgage territory rather than standard buy-to-let, and the valuation will apportion residential and commercial elements even though the SDLT computation does not.
The caution is that HMRC has litigated aggressively against contrived mixed-use claims, paddocks, grazing agreements over the back field, a home office dressed up as commercial premises, and the tribunal record since 2019 runs heavily in HMRC's favour. Genuine mixed-use with a commercial lease in place is robust. Anything that exists mainly on the SDLT return is not.
Buying three flats from the same vendor in three contracts on the same day does not produce three small SDLT computations. Transactions between the same buyer and seller, or persons connected with them, that form part of a single scheme or arrangement are linked: the prices are aggregated, the duty is computed on the total, and it is apportioned back. Linking cuts both ways. It removes the benefit of splitting a purchase into sub-£125,000 slices, but it is also what lets a staged block acquisition reach the six-dwelling threshold for the non-residential election when the units complete in tranches. If you are negotiating a portfolio purchase from one vendor, the linking analysis should be done before heads of terms, not by the solicitor at completion.
SDLT is due within 14 days of the effective date, almost always completion, on a return filed by your solicitor. LBTT and LTT returns are due within 30 days. In practice every solicitor requires cleared duty funds before completing, so the duty is a day-one cash item alongside the deposit, not something to settle out of the first quarter's rent.
At portfolio scale that day-one cash is routinely raised from the existing book rather than from savings. A landlord with £180,000 of available equity across four unencumbered or low-geared properties can release it through a buy-to-let remortgage or a portfolio facility and fund both the 25% deposit and the £20,000 duty on the next purchase. Capital raised this way is debt secured for the purpose of the lettings business, and on a time-critical purchase, an auction, a receiver sale, a vendor who will not wait for a term mortgage, the same job is done by a bridging loan with the term refinance as the exit. The point is sequencing: the duty is knowable to the pound before exchange, so the funding line for it should be agreed before exchange too.
As of June 2026 a £300,000 buy-to-let in England or Northern Ireland attracts £20,000 of SDLT: 5% on the first £125,000 (£6,250), 7% on £125,001 to £250,000 (£8,750) and 10% on the final £50,000 (£5,000). The 5% additional dwelling surcharge, raised from 3% on 31 October 2024, accounts for £15,000 of that bill. An owner-occupier buying the same property would pay £5,000.
Yes. A company purchasing any residential dwelling in England or Northern Ireland pays the 5% SDLT surcharge on every band regardless of whether it is the company's first property. There is no first-purchase exemption for companies. In Scotland a company pays the 8% LBTT Additional Dwelling Supplement on every residential purchase of £40,000 or more, and in Wales companies always pay the LTT higher residential rates.
Companies buying a single dwelling for more than £500,000 in England or Northern Ireland are charged a flat 17% SDLT rate (raised from 15% on 31 October 2024) unless a relief applies. Genuine property rental businesses qualify for relief and pay the normal surcharged residential rates instead, but claiming the relief brings the property into the ATED regime, with an annual ATED return required even when the rental-business exemption reduces the annual charge to nil.
Where six or more dwellings are purchased in a single transaction, HMRC allows the buyer to apply non-residential SDLT rates (0% to £150,000, 2% to £250,000, 5% above) instead of surcharged residential rates. On a six-flat purchase at £1,500,000 in June 2026, surcharged residential rates produce £168,750 of SDLT while non-residential rates produce £64,500, a saving of £104,250. Since Multiple Dwellings Relief was abolished on 1 June 2024, this is the main remaining structural relief for bulk purchases.
In England and Northern Ireland the SDLT return and payment are due within 14 days of completion. In Scotland the LBTT return is due within 30 days, and in Wales the LTT return is due within 30 days. Solicitors will not normally complete without cleared funds for the duty, so the cash has to be in place alongside the deposit on completion day, not afterwards.
Yes. Multiple Dwellings Relief (MDR), which averaged the price across dwellings bought in one transaction, was abolished for SDLT transactions completing on or after 1 June 2024. Portfolio buyers in England and Northern Ireland now rely on the 6+ dwellings non-residential rate election and mixed-use classification. Scotland and Wales retain their own multiple-dwellings reliefs within LBTT and LTT, which is one reason cross-border portfolio purchases need nation-by-nation computation.
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