SDLT vs LBTT vs LTT: the three UK property transaction taxes compared (2026)

Buy the same £300,000 home in three different parts of the United Kingdom and you face three different tax bills. In England (or Northern Ireland) the bill is £5,000. In Scotland it is £4,600. In Wales it is £4,500. The transaction is identical; the paperwork, the rate cards and the authorities collecting the money are not.

This guide sets out, side by side, how the three UK property transaction taxes work in 2026: Stamp Duty Land Tax (SDLT) in England and Northern Ireland, Land and Buildings Transaction Tax (LBTT) in Scotland, and Land Transaction Tax (LTT) in Wales. It draws on the published rate tables of each authority — HMRC, Revenue Scotland and the Welsh Revenue Authority — and on worked examples from the Homecost calculator engine. Figures fetched 17 May 2026.

This is general information, not advice. The interaction between residence, joint-buyer rules, partial-owner reliefs and additional-dwelling exposure can change the bill materially. Speak to a qualified conveyancer or tax adviser before completing a purchase.

Why three taxes for one Union

When the original Stamp Duty Land Tax was introduced under the Finance Act 2003, it applied across the whole of the United Kingdom. Devolution changed that. The Scotland Act 2012 transferred SDLT in Scotland to the Scottish Parliament; LBTT replaced SDLT north of the border on 1 April 2015 under the Land and Buildings Transaction Tax (Scotland) Act 2013. The Wales Act 2014 did the same for Wales; LTT replaced SDLT on Welsh transactions on 1 April 2018 under the Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017.

Northern Ireland was not devolved a transactions tax — SDLT continues to apply there on the same terms as England.

The practical consequence: every UK residential purchase falls under one (and only one) of these three regimes, determined by the location of the property — not the buyer's residency, not the buyer's nationality, not where the conveyancer is based. A French buyer of a Cardiff flat pays LTT to the Welsh Revenue Authority. A Glasgow resident buying a London pied-à-terre pays SDLT to HMRC.

The three standard rate tables, side by side

The tables below show the standard residential rates in force on 17 May 2026. They apply to a sole owner buying a single primary residence — no first-time-buyer relief, no additional-dwelling exposure, no non-resident surcharge.

England & Northern Ireland — SDLT

Scotland — LBTT

Wales — LTT

Three immediate structural differences are worth pinning down.

Where the nil-rate ends. SDLT in England runs the nil-rate to £125,000. LBTT in Scotland is £20,000 higher at £145,000. Wales LTT is much higher still at £225,000 — almost a third higher than the SDLT nil-rate. At today's regional median prices, an LTT buyer in Wales is statistically far more likely to pay nothing at all than an SDLT buyer in England.

Where the second slab tops out. SDLT and LBTT both end the 2% slab at £250,000, so under £250,000 the two regimes behave broadly similarly. LTT has no 2% slab at all — the moment a Welsh transaction crosses £225,000 the rate jumps straight to 6%, the steepest entry rate in the UK.

Where the headline top slab kicks in. SDLT's 12% top slab starts at £1.5m. LTT's 12% slab matches that. LBTT's 12% slab kicks in much earlier, at £750,000 — making expensive Scottish purchases proportionally costlier than their English equivalents at the top end.

Four worked examples, three regimes

What does each rate card actually cost in practice? Below are four price points — £200,000, £300,000, £500,000 and £750,000 — calculated against each standard residential rate table. Numbers below are the engine output from the Homecost SDLT calculator, cross-checked against the published rate tables of HMRC, Revenue Scotland and the Welsh Revenue Authority.

At £200,000 Wales is cheapest by £1,100-£1,500 — the high £225,000 nil-rate threshold means the transaction is tax-free. At £300,000 the three regimes converge within £500 of each other. By £500,000 the picture has flipped: England is now the cheapest, with Scotland costing £8,350 more and Wales £3,000 more than the SDLT bill. At £750,000 the gap widens dramatically — a Scottish LBTT buyer pays £20,850 more than an English SDLT buyer for the same headline price.

The driver at the top end is structural: LBTT's 10% slab starts at £325,001, not £925,001. A £750,000 Edinburgh purchase clears £42,500 of LBTT just from the £325,000-£750,000 slab. The same £750,000 spent in London produces £25,000 of SDLT from the £250,000-£925,000 slab. Same headline price, very different effective rates: 6.45% in Edinburgh, 3.67% in London.

First-time buyer relief: three completely different rule sets

Each of the three regimes treats first-time buyers differently. The reliefs are not interchangeable and, in Wales, do not exist at all.

England (SDLT FTB relief)

First-time buyers buying their only or main residence at £500,000 or less pay no SDLT on the first £300,000 and 5% on the slice between £300,000 and £500,000. Purchases above £500,000 receive no FTB relief at all — the cliff edge documented in our £500,000 stamp duty cliff edge analysis.

A first-time buyer paying £300,000 in England pays £0 SDLT (vs £5,000 for a non-FTB). A first-time buyer paying £500,000 pays £10,000 SDLT (vs £15,000 for a non-FTB). A buyer paying £500,001 pays £15,000 — exactly £5,000 more than the buyer at £500,000.

For the eligibility rules — what counts as "first-time", what shared-ownership treatment looks like, and how joint-buyer status interacts — see our stamp duty first-time buyer relief explainer.

Scotland (LBTT FTB relief)

Scotland operates a separate first-time-buyer relief introduced in June 2018. It raises the LBTT nil-rate band for qualifying first-time buyers from £145,000 to £175,000. Above £175,000, the normal LBTT bands apply unchanged. The maximum relief is therefore £600 (the 2% LBTT that would otherwise be due on the £145,000-£175,000 slice).

This is materially smaller than the English relief. A Scottish first-time buyer paying £300,000 pays £4,000 LBTT — the same as if relief did not exist on a £180,000 purchase, plus the full 2%/5% slab bills above £175,000. There is no tapered relief above the threshold and no cliff edge equivalent to the SDLT £500,000 point.

Wales (no FTB relief)

Wales has not operated a first-time-buyer relief since LTT was introduced in April 2018. The Welsh Revenue Authority's published position is that the higher general nil-rate threshold (£225,000 in 2026, vs £125,000 in England) is itself the support mechanism for entry-level buyers, and that a separate FTB relief would compound it without adding meaningful targeting.

The net effect: a Welsh first-time buyer paying £200,000 pays £0 LTT (same as an English FTB at the same price). A Welsh first-time buyer paying £300,000 pays £4,500 LTT — £4,500 more than the English FTB equivalent of £0. Wales is the only UK regime where first-time buyers can pay more tax than equivalents in England.

Additional dwellings: three different surcharge structures

The treatment of second homes, buy-to-let purchases and corporate buyers is where the three regimes diverge most sharply.

England SDLT applies a flat 5% additional dwellings surcharge on the full purchase price (above the £40,000 threshold), on top of the standard SDLT slabs. The surcharge rose from 3% to 5% on 31 October 2024 under the Autumn Budget 2024. A £300,000 second-home purchase in England now produces £5,000 standard SDLT + £15,000 surcharge = £20,000 total — see our additional property surcharge explainer for the detail.

Scotland LBTT applies the Additional Dwelling Supplement (ADS) at 8% of the full purchase price above the £40,000 threshold. The ADS rose from 6% to 8% on 5 December 2024 under the Scottish Budget 2025-26. A £300,000 second home in Scotland now produces £4,600 standard LBTT + £24,000 ADS = £28,600 total — the heaviest second-home charge anywhere in the UK at this price point.

Wales LTT is structurally different. There is no flat surcharge added to the standard rates; instead, Wales operates a completely separate higher residential rate table for additional-dwelling and corporate purchases, with its own slab structure. The current higher residential rates (as published by the Welsh Revenue Authority) are notably steeper than the standard table from the very first pound — there is no nil-rate band for an additional dwelling in Wales. For the exact band thresholds and percentages in force on the date of any purchase, check the Welsh Revenue Authority rate page directly, as the higher-rate table is reviewed independently of the main table.

In every regime, the additional-dwellings rules look at all dwellings owned worldwide by all buyers on the transaction — including overseas property. Joint buyers can poison reliefs that one party would otherwise qualify for on their own. The interactions are technical, and the refund mechanisms (where a previous main residence is sold within 36 months) differ in the detail.

Non-UK resident purchasers

England SDLT applies an additional 2% non-resident surcharge on top of all other rates for buyers who have not been UK-resident for at least 183 days in the 12 months ending on the effective date of the transaction. The surcharge is refundable if the residence test is satisfied within the 12 months after completion.

LBTT and LTT do not currently operate a residency surcharge. Non-resident buyers of Scottish or Welsh property pay the same LBTT or LTT rates as resident buyers.

That puts a meaningful gap on a £500,000 transaction: a non-resident buyer faces £25,000 SDLT on an English purchase (£15,000 standard + £10,000 of 2% non-resident surcharge) compared with £18,000 LTT on the equivalent Welsh purchase — a £7,000 advantage to the Welsh title from the resident-status differential alone.

Northern Ireland: same rules as England

Northern Ireland is the simplest case. SDLT applies on the same terms as England, with the same rates, the same first-time buyer relief, the same 5% additional-dwellings surcharge and the same 2% non-resident surcharge. There is no devolved Northern Ireland transaction tax. For most search and buyer purposes, "England" and "Northern Ireland" can be read interchangeably in the SDLT context.

What this means for cross-border movers

The three regimes create real friction at the border. A buyer relocating from Newcastle to Edinburgh and offering on a £600,000 property faces a different bill than the same buyer making the same offer on a property in Berwick-upon-Tweed seven miles away. The £600,000 transaction would produce £20,000 of SDLT in Berwick vs £33,350 of LBTT in Edinburgh — a £13,350 gap driven entirely by the location of the property.

For buyers comparing regional options, three useful rules of thumb hold up across the rate tables:

1. Below £225,000, Wales is cheapest. The high LTT nil-rate dominates.
2. Between £225,000 and £350,000, the three regimes are within £600 of one another. The choice barely registers in the cost stack.
3. Above £400,000, England is meaningfully cheapest, with LBTT becoming the most expensive regime by a widening margin as the price rises.

The other component of "true cost" that varies sharply across borders is council tax — Scotland and Wales operate their own band schedules, and the Band D averages diverge materially. To see the council tax band, energy-rated running cost and current SDLT/LBTT/LTT figure for any specific address, use the Homecost postcode lookup with an Edinburgh sample postcode or any other UK postcode.

For more guides in the Cost Intelligence series, including the £500k cliff edge analysis, the joint-buyer trap and the full hidden-cost reserve table, see the catalogue. Each piece in the series draws on HM Land Registry data spanning 30.9 million England-and-Wales transactions and the matching published rate tables of HMRC, Revenue Scotland and the Welsh Revenue Authority.

Disclaimer. This article describes the published transaction-tax rules in force on 17 May 2026 across the three UK regimes. It does not constitute tax or legal advice. Rate cards change at every Budget cycle and devolved Budget cycle, and the interaction with residence tests, joint-buyer status, partial-owner reliefs and additional-dwelling exposure can shift the bill materially. Always consult a qualified conveyancer or tax adviser before exchanging on a purchase, and verify the current rates with HMRC, Revenue Scotland or the Welsh Revenue Authority on the date of your transaction.