Second Home Stamp Duty 2026: 5% Surcharge Rules, Exemptions & Refund Window
How the 5% additional dwellings surcharge works in practice: who it applies to, the exemption edge cases (married couples, joint owners, beneficial interests), the 36-month refund window when you sell your previous home, and what counts as “additional” in HMRC's eyes. Need to calculate the exact bill for your purchase instead?
Key Takeaways
- At £300,000 you pay £20,000 in second home stamp duty (6.67% effective rate). At £500,000 you pay £40,000 (8.00% effective rate). The effective rate rises with price but never equals the 10% headline band rate.
- The surcharge adds exactly 5% of the purchase price to your bill in every case: the "extra" cost is always purchase price multiplied by 0.05. On top of that sits the standard progressive SDLT.
- Surcharge applies if you own two or more residential properties worth £40,000+ anywhere in the world at the end of the day you complete. Married couples and civil partners are treated as one unit.
- No surcharge if you replace your main residence and sell the previous one within 36 months. Inherited shares below 50% are ignored entirely.
- Total cash at completion on a £300,000 second home with a 25% deposit is roughly £93,500 to £96,000 once you include SDLT, legal fees, survey, and Land Registry.
- SDLT cannot be added to a buy-to-let mortgage: the full bill is due within 14 days of completion, so it must come from cash reserves.
- At a 5% gross rental yield, recovering the stamp duty through rent alone takes roughly 40 months on a £300,000 buy-to-let and 48 months on a £500,000 one.
In this article
Second Home SDLT at 5 Key Price Points (England and NI, 2026)
The table below gives you the answer fast. These use the current 2026 rates: the 5% additional dwelling surcharge that has applied since 31 October 2024, combined with the standard SDLT thresholds. All figures are for England and Northern Ireland only. For Scotland and Wales figures, see the regional numbers section below.
| Property Price | Standard SDLT | Second Home SDLT | Surcharge Cost | Effective Rate |
|---|---|---|---|---|
| £200,000 | £1,500 | £11,500 | +£10,000 | 5.75% |
| £300,000 | £5,000 | £20,000 | +£15,000 | 6.67% |
| £500,000 | £15,000 | £40,000 | +£25,000 | 8.00% |
| £750,000 | £27,500 | £65,000 | +£37,500 | 8.67% |
| £1,000,000 | £43,750 | £93,750 | +£50,000 | 9.38% |
Not sure whether the surcharge actually applies to you? Jump to the eligibility rules section below for the ownership test, married-couple unit rule, replacement main residence exemption, inherited property treatment, and other edge cases.
Calculate Your Exact Figure
The table above covers five common prices. If your purchase price is different, use the dedicated calculator to get the precise figure instantly. It handles all the progressive band maths automatically.
Does the Surcharge Apply to You? Eligibility Rules
The 5% surcharge (formally Higher Rates for Additional Dwellings, HRAD) applies when you complete a residential purchase and own two or more residential properties worth £40,000 or more anywhere in the world at the end of completion day. The rate locks at exchange, not completion: contracts exchanged on or before 30 October 2024 still pay the old 3% even if completion is later.
What counts toward your ownership total
Does count
- Any residential property worth £40,000+ in the UK or abroad
- Inherited share of 50% or more
- Property held in trust where you're a life-interest beneficiary
- Property owned for children under 18 (parents are treated as owners)
- Shared ownership properties (your share counts)
- Your current home, if not sold by completion day
Does not count
- Property worth less than £40,000
- Caravans, mobile homes, houseboats (unless permanently fixed)
- Commercial property; mixed-use property
- Inherited share below 50%
- Leases with 7 years or less remaining
Married couples & civil partners: the single-unit rule
Married couples and civil partners are treated as one unit. If either spouse owns another qualifying property, the surcharge applies to any purchase by either of them — including sole-name purchases. The rule continues until the couple is permanently separated (ceased cohabitation with no intention to resume). Unmarried couples are assessed individually.
Replacement main residence: when the surcharge does not apply
The surcharge does not apply if you are replacing your main residence and meet all three conditions:
- The new property will be your only or main residence.
- You have already sold (or will sell within 36 months of completion) your previous main residence.
- The previous property was your main residence at some point in the 3 years before completion.
The 36-month refund window (the “3-year rule” on stamp duty)
This is the 3-year rule on stamp duty for second homes: if you complete on the new property while still owning the old one, you pay the surcharge upfront and reclaim it once you sell — provided the sale happens within 36 months (the three-year window). Selling your original home within three years of buying the new one triggers the refund. Refund must be claimed within 12 months of the sale (or within 12 months of the original SDLT return filing date, whichever is later). See the stamp duty refund complete guide for the claim process.
Inherited property: the 50% rule
Inherited property only counts toward your ownership total when your share is 50% or more. A share below 50% is ignored entirely. The interaction between inheritance and a future purchase can be complex when multiple heirs share a property — see how inheritance affects your stamp duty for the full treatment.
Other key exemptions and edge cases
- Court-ordered divorce transfers are exempt from SDLT entirely, including the surcharge. See divorce and stamp duty.
- Mixed-use property (part residential + part commercial) is taxed at non-residential rates — the higher residential rates do not apply.
- Six or more dwellings in one transaction trigger non-residential SDLT rates, not the higher residential rates. The surcharge does not apply.
- Companies (corporate purchasers) always pay the higher rates on residential purchases of £40,000+. There is no replacement-main-residence exemption for corporate buyers. Properties above £500,000 may attract the 17% corporate rate — see corporate buyer guide.
- Non-UK residents pay an additional 2% surcharge stacked on top of the 5% additional dwelling rate — total combined rates from 7% (band 1) up to 19% (over £1.5m). See non-resident complete guide.
How the 5% Surcharge Works Band by Band
The surcharge adds 5 percentage points to every SDLT rate band. It does not replace the standard rates; it stacks on top of them. The current stamp duty rates for second homes in England and Northern Ireland have applied since 1 April 2025, when the temporary nil-rate thresholds reverted to £125,000 for standard buyers and £300,000 for first-time buyers. The second home surcharge itself rose from 3% to 5% on 31 October 2024. The resulting second home bands are:
| Band | Standard Rate | +5% Surcharge | Second Home Rate |
|---|---|---|---|
| £0 to £125,000 | 0% | +5% | 5% |
| £125,001 to £250,000 | 2% | +5% | 7% |
| £250,001 to £925,000 | 5% | +5% | 10% |
| £925,001 to £1,500,000 | 10% | +5% | 15% |
| Over £1,500,000 | 12% | +5% | 17% |
To show how these bands combine, here is a worked calculation for a £300,000 second home:
Band-by-Band Calculation: £300,000 Second Home
First £125,000 at 5%
(standard 0% + 5pp surcharge)
£125,001 to £250,000 (£125,000) at 7%
(standard 2% + 5pp surcharge)
£250,001 to £300,000 (£50,000) at 10%
(standard 5% + 5pp surcharge)
Key mental shortcut: The extra cost from the surcharge is always exactly 5% of the purchase price. So for any purchase price, multiply it by 0.05 to find the surcharge premium, then add it to the standard SDLT figure (from the top table or from our calculator).
8 Detailed Worked Examples: £150,000 to £1.5 Million
Each example below shows the full band-by-band breakdown plus total acquisition costs. "Total cash at completion" assumes standard acquisition fees: conveyancing £1,800, survey £600, Land Registry £295, and a 25% deposit. Mortgage arrangement fees (if applicable) are excluded as these vary. For your specific price, use the second home stamp duty calculator.
Example 1: £150,000
Band calculation:
Acquisition summary:
Example 2: £200,000
Band calculation:
Acquisition summary:
Example 3: £300,000 (most searched price)
Band calculation:
Acquisition summary:
Example 4: £400,000
Band calculation:
Acquisition summary:
Example 5: £500,000
Band calculation:
Acquisition summary:
Example 6: £750,000
Band calculation:
Acquisition summary:
Example 7: £1,000,000
Band calculation:
Acquisition summary:
Example 8: £1,500,000
Band calculation:
Acquisition summary:
Effective Rate Analysis
The effective rate is the total SDLT bill divided by the purchase price. It rises as the purchase price climbs through higher bands but never reaches the headline band rate (because lower bands always apply to the first portions of the price).
| Purchase Price | SDLT Bill | Effective Rate | Headline Band |
|---|---|---|---|
| £150,000 | £8,000 | 5.33% | 7% |
| £200,000 | £11,500 | 5.75% | 7% |
| £300,000 | £20,000 | 6.67% | 10% |
| £400,000 | £30,000 | 7.50% | 10% |
| £500,000 | £40,000 | 8.00% | 10% |
| £750,000 | £65,000 | 8.67% | 10% |
| £1,000,000 | £93,750 | 9.38% | 15% |
| £1,500,000 | £168,750 | 11.25% | 15% |
Rate progression pattern
The effective rate starts at 5.33% at £150,000 (where only the two lowest bands apply) and climbs steadily. It crosses 7.5% around £400,000, hits 8% at £500,000, and reaches 11.25% at £1.5 million. The effective rate can never quite match the headline band rate because the lower bands always bring the average down.
Total Acquisition Cost Template
SDLT is just one of several upfront costs. The table below shows how the full cash requirement grows across four price points at a 25% deposit. It illustrates why SDLT planning matters: at £500,000, the stamp duty alone (£40,000) is 22% of your total cash outlay and larger than the typical conveyancing and survey bills combined.
| Cost Item | £200k | £300k | £500k | £750k |
|---|---|---|---|---|
| Deposit (25%) | £50,000 | £75,000 | £125,000 | £187,500 |
| Second home SDLT | £11,500 | £20,000 | £40,000 | £65,000 |
| Conveyancing (est.) | £1,500 | £1,800 | £2,000 | £2,500 |
| Survey (Level 2) | £400 | £600 | £700 | £800 |
| Land Registry fee | £135 | £270 | £295 | £295 |
| Total cash required | ~£63,535 | ~£97,670 | ~£167,995 | ~£256,095 |
| SDLT as % of total cash | 18.1% | 20.5% | 23.8% | 25.4% |
Fees are estimates based on typical 2026 market rates. Conveyancing costs vary by solicitor and property complexity. Mortgage arrangement fees (typically £0 to £2,000) are excluded. For a buy-to-let purchase, also budget for a landlord buildings insurance quote before exchange.
Mortgage and Cash Planning
Unlike a residential remortgage where some buyers try to roll costs into the loan, SDLT on a second home or buy-to-let purchase cannot be added to the mortgage. The stamp duty must be paid from your own cash within 14 days of completion. This is the single most common cash-flow surprise for buyers: on a £400,000 buy-to-let, you need £30,000 in liquid cash on top of your deposit, purely for SDLT, and it cannot come from the lender.
Cash planning rule: Add the SDLT figure to your deposit when calculating how much liquid cash you need. For a £300,000 buy-to-let at 25% LTV, your cash requirement is £75,000 (deposit) + £20,000 (SDLT) + ~£2,700 (fees) = ~£97,700, not £75,000. For questions about whether the surcharge applies to your situation, see the eligibility rules section above.
Buying soon? Get your stamp duty checked before you commit
A specialist can confirm the right figure and flag any reliefs you qualify for.
Rent Yield Payback Analysis
For buy-to-let investors, a useful planning metric is the SDLT payback period: how many months of gross rent does it take to recover the stamp duty bill? This does not mean the SDLT is "recovered" in a tax sense (it is a capital cost and may form part of your CGT base cost when you sell), but it gives a concrete sense of how the upfront cost affects your investment horizon.
Formula: SDLT payback months = (SDLT bill / annual gross rent) x 12. The table below uses three common gross yield assumptions.
| Purchase Price | SDLT Bill | Payback at 4% yield | Payback at 5% yield | Payback at 6% yield |
|---|---|---|---|---|
| £150,000 | £8,000 | 16 months | 13 months | 11 months |
| £200,000 | £11,500 | 17 months | 14 months | 11 months |
| £300,000 | £20,000 | 20 months | 16 months | 13 months |
| £400,000 | £30,000 | 23 months | 18 months | 15 months |
| £500,000 | £40,000 | 24 months | 19 months | 16 months |
| £750,000 | £65,000 | 26 months | 21 months | 17 months |
These are gross payback figures. Net rental yield (after mortgage interest, agent fees, maintenance, and voids) is typically 1.5 to 3 percentage points lower than gross yield, so the real payback period in terms of net cash flow is considerably longer. Use these figures as a quick filter when comparing investment properties: a higher-yield property recovers the SDLT cost faster even if the nominal SDLT bill is larger.
Scotland and Wales: Raw Numbers at a Glance
Scotland and Wales use separate devolved property tax systems with different rates and thresholds. Scotland levies Land and Buildings Transaction Tax (LBTT) plus an Additional Dwelling Supplement (ADS) of 8% applied to the full purchase price (increased from 6% in December 2024). Wales levies Land Transaction Tax (LTT) with its own higher residential rate band structure for additional properties. The figures below show the total additional-property tax at two common price points. For the full rules of how each system works, see our Scotland LBTT complete guide and Wales LTT complete guide.
| Region | Standard tax at £300k | Additional property at £300k | Additional property at £500k |
|---|---|---|---|
| England (SDLT) | £5,000 | £20,000 | £40,000 |
| Scotland (LBTT + 8% ADS) | £4,600 | £28,600 | £57,100 |
| Wales (LTT higher rates) | £4,500 | ~£16,500 | ~£30,000 |
Scotland figures use current LBTT thresholds plus 8% ADS (flat rate on full purchase price, increased from 6% in December 2024). Wales figures use the current Welsh Revenue Authority higher residential rate band structure. Always verify with the second home calculator before relying on these estimates for a specific property.
5 Calculation Mistakes to Avoid
Calculating 5% of the purchase price as your total bill
On a £400,000 second home, 5% of £400,000 = £20,000. But the actual second home SDLT is £30,000. The 5% is the surcharge premium only; the full bill includes the standard progressive SDLT on top of the surcharge for each band.
Ignoring the £40,000 threshold on the property being purchased
If the second property costs £40,000 or less, no surcharge applies at all. This is rarely relevant in most UK markets but matters for parking spaces, small plots, or low-value rural property classified as residential.
Forgetting that the non-resident surcharge stacks on top
Non-UK residents buying property in England and Northern Ireland pay an additional 2% on top of all other SDLT rates. If you are a non-resident buying a second home, your effective rates are: 7% (band 1), 9% (band 2), 12% (band 3), 17% (band 4), 19% (band 5). On a £500,000 second home as a non-resident, you pay £50,000 rather than £40,000.
Using the pre-October 2024 surcharge rate (3% instead of 5%)
The surcharge increased from 3% to 5% on 31 October 2024. Any calculator or worked example that predates this change will understate your liability by 2 percentage points on every pound of the purchase price. On a £400,000 purchase that is an £8,000 underestimate. Always check that any tool you use reflects the current 5% rate.
Budgeting only the SDLT without the other completion costs
Buyers who budget only the SDLT figure often find themselves short on completion day. Legal fees, survey, Land Registry, and mortgage arrangement fees typically add £2,500 to £5,000 on top of SDLT. On a £300,000 purchase, the total completion cost excluding deposit is closer to £23,000, not £20,000.
How to Legally Avoid or Reduce the Surcharge
There are five legitimate routes to avoid or reduce the additional property surcharge. Which one applies depends on your circumstances, and none relies on aggressive avoidance that HMRC can challenge under its anti-avoidance powers.
Sell before you complete
The simplest route: exchange and complete on the sale of your current main residence before, or on the same day as, your purchase. This avoids the surcharge entirely without relying on a refund.
Pay up front and claim a refund
If your sale is delayed, pay the surcharge at completion and reclaim it once your previous main home sells, provided that happens within 36 months. You have 12 months from the sale date to lodge the claim.
Single dwelling with a granny annexe
A property with a self-contained annexe can be treated as a single dwelling, provided the annexe is worth less than one-third of the total property value. Multiple Dwellings Relief, which previously offered an alternative route, was abolished from 1 June 2024.
Mixed-use classification
A property with a genuine non-residential element (for example a shop below a flat) may fall under non-residential rates, which carry no surcharge. HMRC applies this strictly: a home office or a paddock is usually not enough.
Stay under £40,000
Purchases below £40,000 attract no surcharge at all. This rarely applies to mainstream homes, but it is relevant for small plots, parking spaces, or lock-up garages.
Scotland ADS rate history
Scotland's Additional Dwelling Supplement has risen steeply since it was introduced. The rate that applies is the one in force on your effective date, which is usually completion.
| Period | ADS rate |
|---|---|
| Before 25 January 2019 | 3% |
| 25 Jan 2019 to 15 Dec 2022 | 4% |
| 16 Dec 2022 to 4 Dec 2024 | 6% |
| From 5 Dec 2024 | 8% |
Free second home surcharge guide (PDF)
A print-ready summary of the rates, refund process, and avoidance routes.
Related guides
- Run your own numbers with the second home stamp duty calculator.
- Buy-to-let investor? See buy-to-let stamp duty cost examples.
- Reclaiming the surcharge after selling your old home? See the stamp duty refund complete guide.
- Portfolio investor buying 6 or more properties? See portfolio landlord stamp duty.
What Is the Second Home Tax Loophole?
The “second home tax loophole” usually refers to one of four routes historically used to avoid the additional-property surcharge. Most have now been closed off by HMRC or by legislation:
1. Multiple Dwellings Relief (MDR) — closed 1 June 2024
MDR previously let buyers of two or more dwellings in one transaction calculate SDLT using the average rate, often producing a lower bill than the surcharge. It was abolished from 1 June 2024 and is no longer available for second home purchases. Transactions that exchanged before 1 June 2024 but completed after still qualify under transitional rules.
2. The granny-annexe route — still valid, narrowly construed
A property with a self-contained annexe can be treated as a single dwelling, avoiding the surcharge, provided the annexe is worth less than one-third of the total property value and is dependent on the main house. HMRC applies this strictly: a self-contained unit with its own independent access rented to a third party does not qualify.
3. Mixed-use classification — genuine commercial use only
A property with a genuine non-residential element (e.g. a shop below a flat, or a working farm) can fall under non-residential SDLT rates, which carry no second home surcharge. HMRC’s test is strict: a home office, a paddock, or occasional business use does not move a residential property into mixed-use territory.
4. Putting a property in a spouse’s name — does not work for married couples
Because married couples and civil partners are assessed as a single unit, transferring ownership of the marital home or buying in one spouse’s sole name does not avoid the surcharge if the other spouse owns property. The route can work for unmarried couples where only one partner owns property, since they are assessed individually.
Bottom line: no legal “loophole” reliably avoids the surcharge for a straightforward second home purchase. The only legitimate routes are to sell your previous main home first (or within 36 months under the 3-year rule), buy a property priced under £40,000, or purchase a genuinely mixed-use property. Aggressive avoidance schemes are routinely challenged by HMRC under section 75A Finance Act 2003.
Will Second Home Stamp Duty Be Scrapped?
Second home stamp duty is not likely to be scrapped. Since the surcharge was introduced in April 2016 it has been raised twice:
- The main HRAD rate in England and Northern Ireland rose from 3% to 5% on 31 October 2024.
- Scotland’s ADS rose from 4% to 6% in December 2022, then to 8% from 5 December 2024.
The political direction of travel has been to raise, not abolish, the additional-property surcharge. The Labour government elected in July 2024 confirmed the 5% rate and retained the 2% non-resident surcharge; the 1 April 2025 threshold reset reverted standard nil-rate bands but did not alter the second home rates. Reform proposals (such as replacing SDLT with an annual property value tax) remain long-term policy debate rather than active legislation.
Treat any “stamp duty is being scrapped” headline with scepticism. The standard SDLT thresholds may change at future Budgets, but the 5% second home surcharge is entrenched policy and a meaningful revenue line for HMRC: scrapping it would require deliberate legislation, not inertia.
Frequently Asked Questions
How much stamp duty do I pay on a £300,000 second home?
You pay £20,000 in stamp duty on a £300,000 second home in England or Northern Ireland (2026 rates). The calculation: £125,000 at 5% = £6,250; then £125,000 at 7% = £8,750; then £50,000 at 10% = £5,000. Total: £20,000. The effective rate is 6.67%. A standard buyer (first or main home) on the same property would pay £5,000, so the surcharge adds £15,000 to the bill.
What is the effective SDLT rate on a second home purchase?
The effective rate varies by price point. At £200,000 it is 5.75%; at £300,000 it is 6.67%; at £500,000 it is 8.00%; at £1,000,000 it is 9.38%; at £1,500,000 it is 11.25%. The effective rate is always lower than the headline band rate because the lower bands (5% and 7%) apply to the first £250,000 of every purchase, regardless of total price. The effective rate cannot match the 10%, 15%, or 17% headline rates but continues rising asymptotically toward the top band as price increases.
How long does it take to recoup second home stamp duty through rental income?
At a 5% gross rental yield, the SDLT payback period ranges from 13 months at £150,000 to 21 months at £750,000. At a lower 4% gross yield, the same range is 16 to 26 months. These are gross figures only: net rental income after mortgage interest, management fees, and voids is lower, so the true payback period in net cash terms is longer. The SDLT also contributes to your capital gains base cost, partially offsetting the cost when you eventually sell.
What are the total upfront costs for a second home purchase?
Total upfront costs for a second home include the deposit, SDLT, conveyancing fees (typically £1,500 to £2,500), a survey (£400 to £800 for a Level 2 HomeBuyer Report), Land Registry fees (£135 to £295 for a registered property), and any mortgage arrangement fee. At £300,000 with a 25% deposit, the total cash needed is approximately £97,500 to £98,500. At £500,000 with a 25% deposit, the total is approximately £167,000 to £168,500. SDLT accounts for around 20 to 24% of total cash outlay at these price points, making it the largest single cost after the deposit.
How much does the non-resident surcharge add to a second home purchase?
Non-UK residents buying additional property in England and Northern Ireland pay both the 5% additional dwelling surcharge and the 2% non-resident surcharge, stacked on top of the standard SDLT rates. The non-resident surcharge adds exactly 2% of the purchase price to the bill. At £300,000 it adds £6,000 (total SDLT: £26,000 instead of £20,000). At £500,000 it adds £10,000 (total: £50,000 instead of £40,000). The residency test uses a 183-day presence rule over the 12 months before completion; the rules are set out in full on HMRC's guidance pages.
What is the 3-year rule on stamp duty?
The 3-year rule (also called the 36-month rule) is the replacement-main-residence exception. If you sell your previous main residence and buy a new home within three years, you can either avoid the second home surcharge entirely or claim a stamp duty refund for the 5% surcharge portion. You must claim within 12 months of the sale date or the original SDLT return filing date, whichever is later.
Can you claim back stamp duty on a second home?
Yes. If you sell your previous main residence within 36 months of buying the new property, you can claim back the second home stamp duty you paid. The refund equals the 5% surcharge portion of your SDLT bill. Typical refund: £15,000 at a £300,000 purchase, £25,000 at £500,000, £37,500 at £750,000. See the stamp duty refund complete guide for the claim process and deadlines.
Does owning property abroad affect second home stamp duty in the UK?
Yes. Overseas property counts toward your ownership total. If you own a residential property abroad worth £40,000 or more and you buy a second property in England or Northern Ireland, you pay the 5% second home surcharge. The test is worldwide ownership, not UK-only.
Are there any exemptions to second home stamp duty?
Exempt categories include: any property under £40,000; caravans, mobile homes and houseboats (unless permanently moored or fixed); genuine mixed-use and commercial property (taxed at non-residential rates); transactions involving six or more dwellings in a single deal (non-residential rates apply); and court-ordered divorce transfers of the marital home. Inherited shares below 50% are ignored for the ownership count.
Do first-time buyers pay the second home surcharge?
First-time buyer relief and the second home surcharge are mutually exclusive. If this is genuinely your first property purchase and you have never owned property anywhere in the world, you qualify for first-time buyer relief and the surcharge does not apply. If you already own property elsewhere (including overseas or inherited property of 50% or more), you pay the higher rate of stamp duty and lose first-time buyer relief.
Will second home stamp duty be scrapped?
No, second home stamp duty is not likely to be scrapped. The surcharge has been raised twice since it was introduced in April 2016 (from 3% to 5% in England and Northern Ireland from 31 October 2024; Scotland's ADS rose to 8% from December 2024). The Labour government elected in July 2024 confirmed the 5% rate. Reform proposals remain long-term policy debate, not active legislation. See the detailed section above.
Notable Additional-Dwelling Case Law
HMRC's 5% additional-dwelling surcharge (HRAD) is one of the most disputed areas of SDLT. Key cases that shape how HRAD is interpreted in practice include Sehgal v HMRC (replacement-of-main-residence dispute, eligibility during a chain of transactions); the broader Tretyakov v HMRC line on mixed-use classification (which can determine whether HRAD even applies); and Hyman v HMRC on the related question of what counts as “suitable for use as a dwelling”.
The most relevant 2025/2026 development is the Tower One St George Wharf v HMRC [2026 EWCA Civ 1588] ruling, where the Court of Appeal expanded HMRC's section 75A anti-avoidance powers over structured intra-group transactions that produce SDLT savings. See the landmark stamp duty cases reference for full case analysis, and the refund rejections and appeals guide if you need to challenge an HMRC HRAD assessment.
Reviewed by
Emma Richardson, MRICS
Chartered Surveyor & Property Tax Specialist
Emma Richardson is a RICS-qualified Chartered Surveyor with over 12 years of experience in UK property taxation. She founded Calculate My Stamp Duty UK to help buyers understand the complex world of property transaction taxes.