Buy a £400,000 second home or rental property in Scotland and the Additional Dwelling Supplement alone adds £32,000 to the bill. The identical purchase in England or Wales adds £20,000 or £20,500. The rates differ sharply — but the underlying design is exactly the same in all three nations: a flat percentage of the full price, charged from the very first pound, with no nil-rate band to soften it. That's a genuinely different shape from first-time buyer relief, which — as we've shown separately — varies wildly in structure across the same three borders. The surcharge doesn't vary in structure at all. It only varies in rate.

Same mechanism, three different rates

England, Wales and Scotland each apply an extra charge on top of standard property transaction tax when the buyer will own more than one residential property at the end of the day of completion — most commonly a second home, a holiday let or a buy-to-let purchase, though the rule also catches people who complete on a new home before selling their existing one. None of the three softens this with a starting allowance:

  • England adds a flat 5 percentage points to the standard Stamp Duty Land Tax (SDLT) bands, from £0 (HMRC, 2026).
  • Wales adds a flat 5 percentage points to standard Land Transaction Tax (LTT), also from £0 (Welsh Revenue Authority).
  • Scotland's Additional Dwelling Supplement (ADS) adds a flat 8 percentage points to standard Land and Buildings Transaction Tax (LBTT), again from £0 (Revenue Scotland).

Checked against Homecost's stamp duty engine across a £150,000–£1,000,000 price ladder (fetched 2026-09-06), the surcharge component holds at exactly that percentage of the full purchase price at every point tested — no cliff, no taper, no threshold below which it doesn't apply:

Purchase priceEngland surcharge (5%)Wales surcharge (5%)Scotland ADS (8%)
£150,000£7,500£7,500£12,000
£200,000£10,000£10,000£16,000
£250,000£12,500£12,500£20,000
£300,000£15,000£15,000£24,000
£400,000£20,000£20,000£32,000
£500,000£25,000£25,000£40,000
£750,000£37,500£37,500£60,000
£1,000,000£50,000£50,000£80,000

England and Wales land on identical figures throughout this table for a simple reason: both charge exactly 5%, so 5% of the same price is the same number either side of the border. Scotland's 8% rate produces a bill that's 60% higher than England's or Wales's at every price point, because 8 is 60% more than 5 — not because Scottish property is taxed under some more complex formula.

The total bill: standard rate plus surcharge

The surcharge sits on top of each nation's own standard rate, and those standard rates aren't identical to start with — Wales's LTT and Scotland's LBTT both rise faster than England's SDLT once you're above the mid-market (we've mapped the exact prices where one regime overtakes another in our SDLT-vs-LTT-vs-LBTT crossover analysis). So the real-world total an additional-property buyer pays is the standard bill plus the flat surcharge above:

Purchase priceEngland totalWales totalScotland total
£150,000£8,000£7,500£12,100
£200,000£11,500£10,000£17,100
£250,000£15,000£14,000£22,100
£300,000£20,000£19,500£28,600
£400,000£30,000£30,500£45,350
£500,000£40,000£43,000£63,350
£750,000£65,000£74,250£108,350
£1,000,000£93,750£111,750£158,350

The cash gap between the cheapest and most expensive nation widens fast as the price rises. At £150,000, the difference between England's total and Scotland's is £4,100. At £1,000,000, it's £64,600 — more than 15 times bigger, even though the purchase price has only grown seven-fold. None of that is a change in policy or a new tax band appearing further up the scale. It's simple proportional arithmetic: a fixed percentage of a bigger number is a bigger number, and because the surcharge has no ceiling and no upper band of its own, it keeps scaling with the full price indefinitely.

Why this is the opposite of first-time buyer relief

It's worth setting this against the first-time buyer relief comparison, because the two features could not be more different in shape. Relief varies enormously by nation: England offers a wide nil-rate band that vanishes in a hard cliff above £500,000 (worth up to £5,000 — more on that cap here); Wales offers no first-time buyer relief at all; Scotland offers a narrow band worth a flat £600 that never disappears, however high the price climbs. Three nations, three completely different policy designs, built for the same stated goal.

The additional-property surcharge shows the opposite pattern. All three nations reach for the same tool — a flat percentage from the first pound, no band of its own — and simply dial the rate differently. Where relief is a case study in policy divergence, the surcharge is a case study in policy convergence. The only real design choice each government made was the number: 5, 5 or 8.

Who this actually affects

The surcharge isn't limited to landlords. It applies to anyone who will own more than one residential property at the end of completion day — a couple buying a holiday home, someone who inherits a property and later buys a home of their own without selling it first, or a buyer who completes on a new main residence before their old one sells (usually reclaimable later if the previous home sells within three years). For scale, of the 742,377 category-A residential sales recorded in England in 2025, just over half (50.8%) were at or above £300,000 — the price band where these totals start to bite hardest; in Wales, where LTT's standard bands are structured differently, the equivalent share was 26.0% of 40,226 sales (HM Land Registry Price Paid Data, 2025, queried 2026-09-06).

This is general information about how the rules are structured, not advice on whether a purchase counts as an "additional property" in your specific circumstances — that depends on completion timing, marital status and prior ownership in ways a conveyancer needs to check against your facts. Speak to a qualified adviser before acting.

Check your own numbers

Run your own purchase price through the stamp duty calculator with the additional-property surcharge applied, or see the full cost picture behind a real address such as CF24 3AA in Cardiff. For more on how the UK's transaction taxes compare across borders, browse our cost intelligence guides.

Based on live HMRC, Welsh Revenue Authority and Revenue Scotland rate tables (fetched 2026-09-06) and 782,603 HM Land Registry category-A transactions across England and Wales in 2025. See how we source our data.