Is Stamp Duty the Same in Scotland and England?
Understanding the key differences between LBTT and SDLT systems.
Quick Answer: No, Scotland has its own system called LBTT (Land and Buildings Transaction Tax) since April 2015, with different rates, bands, and surcharges from England's SDLT.
Key Takeaways
- Scotland has its own system called LBTT (Land and Buildings Transaction Tax) since April 2015, replacing SDLT
- Scotland's ADS (Additional Dwelling Supplement) is 8% vs England's 5% higher rate surcharge
- Scotland's first-time buyer relief threshold is £175,000 vs England's £300,000
- On a £300,000 home, a standard buyer pays £5,000 SDLT in England but £4,600 LBTT in Scotland; a first-time buyer pays £0 in England and £4,000 in Scotland
- Scotland LBTT filing deadline is 30 days vs 14 days for SDLT in England
- Revenue Scotland collected £804m in LBTT during 2023-24
Overview of the Two Systems
No, stamp duty is not the same in Scotland and England. Scotland has operated its own separate property transaction tax system called LBTT (Land and Buildings Transaction Tax) since April 2015, while England continues to use SDLT (Stamp Duty Land Tax). These two systems have different rates, bands, thresholds, and reliefs. Use our stamp duty calculator to see exact costs for properties in either region.
When Scotland gained devolved tax powers, it chose to replace SDLT with its own system. Both taxes work on a progressive basis where you pay different rates on portions of the property price, but the specific bands and rates differ significantly.
Key System Differences
England (SDLT)
- • Administered by HMRC
- • 14-day filing deadline
- • FTB relief up to £500,000
- • 5% higher rate surcharge
- • Zero-rate threshold: £125,000
Scotland (LBTT)
- • Administered by Revenue Scotland
- • 30-day filing deadline
- • FTB relief up to £175,000
- • 8% ADS surcharge
- • Zero-rate threshold: £145,000
Revenue Scotland collected £804 million in LBTT during 2023-24, demonstrating the significant scale of Scotland's property market. The Scottish Government has used its tax powers to set rates that reflect its own housing policy priorities, particularly regarding affordable housing and second home ownership. For detailed guidance, see our Scotland LBTT guide or use our Scotland LBTT calculator for an exact figure.
Side-by-Side Rate Comparison
The most obvious difference between SDLT and LBTT is in their rate bands. Here's a direct comparison for residential properties (standard rates, not additional properties):
| Property Price Band | England SDLT Rate | Scotland LBTT Rate |
|---|---|---|
| £0 - £125,000 | 0% | 0% |
| £125,001 - £145,000 | 2% | 0% |
| £145,001 - £250,000 | 2% | 2% |
| £250,001 - £325,000 | 5% | 5% |
| £325,001 - £750,000 | 5% | 10% |
| £750,001 - £925,000 | 5% | 12% |
| £925,001 - £1,500,000 | 10% | 12% |
| Over £1,500,000 | 12% | 12% |
The key difference in this range is the nil-rate band. England charges 0% up to £125,000 then 2% from £125,001 to £250,000, while Scotland charges 0% up to £145,000 then 2% from £145,001 to £250,000. Scotland's higher nil-rate band makes it slightly cheaper up to about £333,000. Above that the Scottish 10% band, which starts at £325,001 against England's £925,001, takes over and Scotland becomes the more expensive of the two.
First-Time Buyer Relief Comparison
Both systems offer relief for first-time buyers, but England's relief is significantly more generous:
England FTB Relief
- • No SDLT on properties up to £300,000
- • 5% only on portion from £300,001-£500,000
- • Relief unavailable on properties over £500,000
Example: £425,000 property = £6,250 SDLT (5% on £125,000)
Scotland FTB Relief
- • No LBTT on properties up to £175,000
- • Standard rates apply above £175,000
- • No upper limit on property value
Example: £425,000 property = £15,250 LBTT (£600 less than a standard buyer)
This means a first-time buyer purchasing a £350,000 property would pay £2,500 in England but £7,750 in Scotland, a difference of £5,250. For properties between £300,000-£500,000, England's FTB relief provides a substantial advantage. Compare these scenarios directly using our England vs Scotland comparison tool.
Additional Property Surcharges
Both systems add surcharges for second homes, buy-to-let properties, and corporate purchases, but Scotland's rate is significantly higher:
England Higher Rate
Added to standard SDLT rates on each band
Example: £300,000 buy-to-let
Standard: £5,000
With surcharge: £20,000
Total difference: +£15,000
Scotland ADS
Additional Dwelling Supplement on entire purchase price
Example: £300,000 buy-to-let
Standard: £4,600
With ADS: £28,600
Total difference: +£24,000
Scotland increased its ADS from 6% to 8% in December 2024, making it 60% higher than England's surcharge. This policy aims to discourage second home ownership and support first-time buyers by reducing competition for properties.
Impact on Buy-to-Let Investors
The higher ADS has made Scotland less attractive for property investment. A landlord buying a £250,000 property pays £20,000 in ADS alone in Scotland, compared to £12,500 in England, an extra £7,500 upfront cost.
Also buying in England or Northern Ireland?
That part of your move pays SDLT, not LBTT or LTT, and owning homes in both can trigger the surcharge.
Filing Deadlines and Administration
The administrative requirements differ between the two systems:
| Aspect | England (SDLT) | Scotland (LBTT) |
|---|---|---|
| Filing Deadline | 14 days after completion | 30 days after completion |
| Administering Body | HMRC | Revenue Scotland |
| Payment Deadline | 14 days after completion | 30 days after completion |
| Late Filing Penalty | £100 (increases if delayed) | £100 (increases if delayed) |
| Online Portal | HMRC SDLT service | Revenue Scotland portal |
Scotland's 30-day deadline provides more breathing room than England's 14-day requirement. However, solicitors in both jurisdictions typically handle the filing and payment as part of the conveyancing process, so buyers rarely need to worry about these deadlines directly.
Worked Examples
Let's compare the actual tax liability for identical properties in England and Scotland across different price points:
Example 1: £250,000 Property (Standard Rate)
England SDLT
- £0 - £125,000 at 0% = £0
- £125,001 - £250,000 at 2% = £2,500
Total SDLT: £2,500
Scotland LBTT
- £0 - £145,000 at 0% = £0
- £145,001 - £250,000 at 2% = £2,100
Total LBTT: £2,100
Scotland costs £400 less
Example 2: £400,000 Property (Standard Rate)
England SDLT
- £0 - £125,000 at 0% = £0
- £125,001 - £250,000 at 2% = £2,500
- £250,001 - £400,000 at 5% = £7,500
Total SDLT: £10,000
Scotland LBTT
- £0 - £145,000 at 0% = £0
- £145,001 - £250,000 at 2% = £2,100
- £250,001 - £325,000 at 5% = £3,750
- £325,001 - £400,000 at 10% = £7,500
Total LBTT: £13,350
Scotland costs £3,350 more
Example 3: £600,000 Property (Standard Rate)
England SDLT
- £0 - £125,000 at 0% = £0
- £125,001 - £250,000 at 2% = £2,500
- £250,001 - £600,000 at 5% = £17,500
Total SDLT: £20,000
Scotland LBTT
- £0 - £145,000 at 0% = £0
- £145,001 - £250,000 at 2% = £2,100
- £250,001 - £325,000 at 5% = £3,750
- £325,001 - £600,000 at 10% = £27,500
Total LBTT: £33,350
Scotland costs £13,350 more
Notice that the gap is not constant. Up to about £333,000 Scotland is the cheaper of the two, by £400 at £250,000, because its nil-rate band is £20,000 higher. Above that the Scottish 10% band starting at £325,001 pulls ahead of England's 5% band, so the gap widens quickly: £3,350 at £400,000 and £13,350 at £600,000.
Which System is Cheaper?
The answer depends on the property price and your circumstances:
Scotland is Cheaper When:
- ✓ You are a standard buyer paying between £125,001 and about £333,000 (up to £400 cheaper, e.g. £2,100 vs £2,500 at £250,000)
England is Cheaper When:
- ✓ You're a first-time buyer purchasing above £175,000
- ✓ Buying an additional property at any price (5% vs 8% surcharge)
- ✓ You are a standard buyer paying more than about £333,000, where Scotland's 10% band applies
Key Insight
For standard buyers the two systems are within £400 of each other up to about £333,000, with Scotland slightly cheaper. Above that, and for first-time buyers above £175,000, England's SDLT is cheaper than Scotland's LBTT. The gap is widest for second homes and buy-to-let properties because of Scotland's 8% ADS.
However, it's important to note that property prices in Scotland tend to be lower than in England on average, which can offset some of the higher tax rates. According to UK House Price Index data, the average property price in Scotland was about £196,000 in July 2026, compared with about £293,000 in England.
Frequently Asked Questions About Scotland vs England Stamp Duty
Do I pay SDLT or LBTT if I move from England to Scotland?
You pay LBTT on any property purchase in Scotland, regardless of where you previously lived. The system is based on where the property is located, not where the buyer resides. If you own a property in England and buy in Scotland, you'll pay the 8% ADS unless you sell your English property within 36 months (extended from 18 months on 1 April 2024).
Can I reclaim LBTT if I pay the 8% ADS then sell my other property?
Yes, if you paid the ADS because you still owned your previous main residence, you can reclaim it if you sell that property within 36 months of buying your new Scottish home. Claim by amending your LBTT return if it is still within its 12-month amendment period; after that, make a claim under section 107 of the Revenue Scotland and Tax Powers Act 2014 within 5 years of the return's filing date. The sale window was extended from 18 months to 36 months on 1 April 2024.
Why is Scotland's ADS higher than England's surcharge?
The Scottish Government increased the ADS from 6% to 8% on 5 December 2024 as a housing policy measure. The aim is to discourage second home ownership and buy-to-let investment, reduce competition for first-time buyers, and generate additional revenue for public services. This reflects Scotland's different approach to housing policy compared to England.
Is stamp duty different in Northern Ireland and Wales too?
In Wales, yes. Wales has its own system called Land Transaction Tax (LTT) since April 2018, with different rates to both England and Scotland. Northern Ireland uses SDLT with exactly the same rates as England. That makes three separate systems across the UK: SDLT (England and Northern Ireland), LBTT (Scotland) and LTT (Wales).
Which system is better for property investors?
England's SDLT system is significantly better for property investors due to its lower 5% surcharge compared to Scotland's 8% ADS. On a £300,000 buy-to-let the England bill is £20,000 against £28,600 in Scotland, so England saves an investor £8,600 upfront.
Does Scotland have a stamp duty holiday like England had?
Scotland and England both implemented temporary nil-rate band increases during COVID-19, but they were different. England raised its threshold to £500,000 from 8 July 2020 to 30 June 2021, then £250,000 to 30 September 2021, while Scotland raised LBTT's threshold to £250,000 from 15 July 2020 to 31 March 2021. Both have since returned to standard rates. Scotland's current nil-rate threshold is £145,000 and England's has been £125,000 since 1 April 2025.
Summary
Stamp duty is definitively not the same in Scotland and England. Scotland's LBTT system has been independent since 2015, with different rates, bands, reliefs, and surcharges. Which system is cheaper depends on the price: Scotland's higher £145,000 nil-rate band helps on lower-value homes, while England's first-time buyer relief (up to £500,000) and lower 5% additional-property surcharge (versus Scotland's 8%) favour buyers in other cases.
When purchasing property, always use the calculator specific to the nation where the property is located. The system is determined by property location, not buyer residence.
Calculate Your Stamp Duty
Use our regional calculators to see exact costs for England or Scotland.
Calculate NowReviewed by
Julie White
ACAStamp duty specialist since 1999Stamp Duty Land Tax Specialist
ACA and Tax Adviser with a career spanning nearly four decades, specialising in stamp duty planning and advisory work since 1999.