Stamp duty is not one tax. It is three, and which one you pay depends entirely on where the property sits. Buy in Manchester and you pay Stamp Duty Land Tax to HMRC. Buy in Glasgow and you pay Land and Buildings Transaction Tax to Revenue Scotland. Buy in Cardiff and you pay Land Transaction Tax to the Welsh Revenue Authority. Northern Ireland stayed with SDLT.
The three systems share a shape, a slice-by-slice progressive rate structure, but the thresholds and percentages are properly different. On some prices Scotland is cheaper. On others it is thousands more expensive. If you are moving between nations, or you are comparing properties on either side of a border, the difference is worth knowing before you make an offer rather than after.
Which tax applies to you
It is the location of the land, not your own address, that decides. A Londoner buying a cottage in Fife pays LBTT. An Edinburgh resident buying a flat in Leeds pays SDLT. Where you live, where you work, and where your solicitor is based make no difference at all.
- England and Northern Ireland: Stamp Duty Land Tax, collected by HMRC.
- Scotland: Land and Buildings Transaction Tax, which replaced SDLT in Scotland on 1 April 2015 and is collected by Revenue Scotland.
- Wales: Land Transaction Tax, which replaced SDLT in Wales on 1 April 2018 and is collected by the Welsh Revenue Authority.
The rate bands side by side
Here is where the three diverge. These are the rates for someone buying a single main residence, with no first-time buyer relief and no additional property surcharge.
England and Northern Ireland (SDLT)
| Portion of price | Rate |
|---|---|
| Up to £125,000 | 0% |
| £125,001 to £250,000 | 2% |
| £250,001 to £925,000 | 5% |
| £925,001 to £1,500,000 | 10% |
| Over £1,500,000 | 12% |
Scotland (LBTT)
| Portion of price | Rate |
|---|---|
| Up to £145,000 | 0% |
| £145,001 to £250,000 | 2% |
| £250,001 to £325,000 | 5% |
| £325,001 to £750,000 | 10% |
| Over £750,000 | 12% |
Wales (LTT, main residential rates)
| Portion of price | Rate |
|---|---|
| Up to £225,000 | 0% |
| £225,001 to £400,000 | 6% |
| £400,001 to £750,000 | 7.5% |
| £750,001 to £1,500,000 | 10% |
| Over £1,500,000 | 12% |
Wales has by far the most generous starting point at £225,000, which takes a large share of Welsh house purchases out of the tax entirely. It then makes that back with a 6% second band where England charges 2%. Scotland starts taxing earliest, at £145,000, and reaches its 10% band at £325,000, a point at which England is still charging 5%.
The same house in three places
Prices matter more than percentages, so here is what a buyer with no reliefs actually hands over at four common price points.
| Purchase price | England and NI | Scotland | Wales |
|---|---|---|---|
| £200,000 | £1,500 | £1,100 | £0 |
| £300,000 | £5,000 | £4,600 | £4,500 |
| £500,000 | £15,000 | £23,350 | £18,000 |
| £800,000 | £30,000 | £54,350 | £41,750 |
Below roughly £325,000 the three systems land in much the same place, and Wales is often the cheapest. Above that, Scotland pulls away sharply because the 10% band arrives so early. At £800,000 a Scottish buyer pays £24,350 more than an English one on an identical price.
First-time buyers get very different deals
This is the biggest gap between the three systems, and it is not close.
England and Northern Ireland give first-time buyers a nil rate up to £300,000 and 5% on the slice between £300,001 and £500,000. Buy for more than £500,000 and the relief vanishes completely, so the maximum saving is £5,000 and it is lost entirely by paying a pound over the cap.
Scotland raises the nil rate band from £145,000 to £175,000 for first-time buyers. The maximum saving is £600, and unlike the English version there is no price ceiling above which it disappears.
Wales has no first-time buyer relief at all. The Welsh position is that the £225,000 starting threshold already does the job for the typical first purchase, which for a lot of Welsh buyers is true.
| First-time buyer price | England and NI | Scotland | Wales |
|---|---|---|---|
| £250,000 | £0 | £1,500 | £1,500 |
| £300,000 | £0 | £4,000 | £4,500 |
| £400,000 | £5,000 | £12,750 | £10,500 |
Second homes and buy-to-let
All three nations charge extra for an additional dwelling, and all three use £40,000 as the price below which the extra charge does not apply. The mechanics differ.
England and Northern Ireland add 5 percentage points to every band, including the band that would otherwise be zero. That surcharge has been 5% since 31 October 2024.
Scotland charges the Additional Dwelling Supplement as a flat percentage of the whole purchase price on top of the ordinary LBTT. ADS rose to 8% for transactions on or after 5 December 2024, up from 6%. Because it applies to the entire price rather than being layered into the bands, it bites hard at every level.
Wales has an entirely separate higher rates table, running from 5% on the first £180,000 up to 17% above £1.5 million. The current higher rates took effect on 11 December 2024.
| £250,000 additional property | Tax due |
|---|---|
| England and Northern Ireland | £15,000 |
| Scotland (£2,100 LBTT plus £20,000 ADS) | £22,100 |
| Wales | £14,950 |
Every one of the three lets you reclaim the extra charge if you were replacing a main residence and you sell the old home within 36 months of buying the new one. The reclaim is not automatic in any of them. Somebody has to ask for it, and if your solicitor has closed the file, that somebody is you.
Overseas Buyers
England and Northern Ireland add a further 2 percentage points for non-UK resident buyers. The test is broadly whether you were in the UK for at least 183 days in the 12 months before the purchase, and if you later meet the residence condition you can amend the return and claim the 2% back, within two years of the transaction.
Neither the Scottish nor the Welsh published rate tables contain a non-resident surcharge. An overseas buyer in Scotland pays LBTT and, where relevant, ADS, with nothing added for residence.
One change on the horizon
Worth knowing if you are buying at the top of the English market: the Budget of 26 November 2025 announced a High Value Council Tax Surcharge, an annual charge on English residential property valued at £2 million or more, intended to start in April 2028. It is levied on owners rather than occupiers, on top of ordinary council tax, and the announced charges run from £2,500 to £7,500 a year depending on value.
Two caveats. It is a council tax surcharge rather than a stamp duty change, so it does not affect what you pay on completion. And as things stand it has been announced and consulted on but not legislated, so the detail can still move. It is England only.
Deadlines and who you pay
The filing windows are not the same either, and this catches out conveyancers working outside their usual jurisdiction.
- SDLT: return and payment within 14 days of completion. Late filing costs £100 up to three months, £200 beyond that, plus interest on the tax.
- LBTT: return within 30 days beginning with the day after the effective date.
- LTT: return and payment within 30 days of the day after completion.
In practice your solicitor files all three, and the money usually comes out of completion funds so you never see it move. What you should see is the figure on the completion statement, and that is the number worth checking against a calculator before the day itself.
What this means when you are comparing properties
If you are house hunting across a border, put the tax in the budget alongside the deposit and the legal fees rather than treating it as an afterthought. A £450,000 house in Berwick and a £450,000 house twenty minutes north of it are not the same purchase, and the gap is large enough to change what you can afford elsewhere in the deal.
Our stamp duty calculator covers the SDLT rates for England and Northern Ireland. For a Scottish or Welsh purchase, work from the band tables above and check the figure with your solicitor before you exchange.