SDLT vs LBTT vs LTT: stamp duty across the UK
England and Northern Ireland use SDLT, Scotland uses LBTT, Wales uses LTT. The three systems share the band-by-band structure but differ in thresholds, surcharges, and first-time buyer relief. On a £300,000 home the SDLT bill is £2,500; in Scotland it is roughly £4,600; in Wales it is around £2,950.
Last reviewed 16 May 2026.
Which one applies?
The tax that applies is determined by the location of the property, not your residence. A buyer living in Edinburgh purchasing a holiday cottage in Cornwall pays SDLT. A buyer living in London purchasing a flat in Glasgow pays LBTT. There is no mix-and-match.
The headline differences
SDLT in England and Northern Ireland
- nil-rate threshold: £125,000
- top rate: 12% above £1.5m
- first-time buyer relief: up to £500,000 (no relief above)
- additional property surcharge: 5%
- non-UK resident surcharge: 2%
LBTT in Scotland
- nil-rate threshold: £145,000
- top rate: 12% above £750,000
- first-time buyer relief: nil rate raised to £175,000 (max saving £600)
- Additional Dwelling Supplement (ADS): 8%
- non-resident surcharge: separate 2% on residential property
LTT in Wales
- nil-rate threshold: £225,000
- top rate: 12% above £1.5m
- first-time buyer relief: none, everyone uses standard rates
- higher residential rate: separate higher-rate band table, not a flat surcharge
Where the gap is largest
Wales has the highest entry threshold by some margin, at £225,000 a Welsh standard buyer pays £0, an English buyer pays £2,000, and a Scottish buyer pays £1,600. But Wales gives no FTB relief, so a first-time buyer in Wales pays more than a first-time buyer in England or Scotland on smaller purchases.
Scotland's top rate kicks in at £750,000, half the threshold in England and Wales, so high-end purchases are taxed more heavily in Scotland. A £1m main-residence purchase pays £41,250 in SDLT, £45,350 in LBTT and £40,950 in LTT.
Surcharge architecture
SDLT and LBTT both apply their additional-property surcharge as a flat addition to every band. SDLT adds 5%, LBTT adds 8% (the Scottish Government raised the ADS from 6% to 8% in December 2024). LTT instead uses a separate "higher residential rate" table, same idea, different plumbing.
Practical implications for cross-border buyers
If you are a non-UK resident, you pay 2% on top in England, Northern Ireland and Scotland. Wales has not introduced a non-resident surcharge.
If you own a home in Scotland and buy a second in Wales, both your existing Scottish home and your new Welsh purchase enter the surcharge picture. The higher residential rates in Wales apply because you own a property elsewhere, regardless of where that property is.