Stamp duty on land is a devolved tax. Since April 2015 Scotland has run its own version — the Land and Buildings Transaction Tax, LBTT — administered by Revenue Scotland. Since April 2018 Wales has done the same, under the Land Transaction Tax, or LTT, administered by the Welsh Revenue Authority. England and Northern Ireland still use Stamp Duty Land Tax, or SDLT, administered by HMRC. The three regimes share the same basic shape — a progressive tax on the purchase price of land — but the bands, rates, surcharges, and reliefs differ in ways that can produce dramatically different tax bills on the same purchase.
The standard residential bands
SDLT (England and Northern Ireland), from 1 April 2025: 0% to £125,000; 2% to £250,000; 5% to £925,000; 10% to £1.5m; 12% above.
LBTT (Scotland): 0% to £145,000; 2% to £250,000; 5% to £325,000; 10% to £750,000; 12% above.
LTT (Wales): 0% to £225,000; 6% to £400,000; 7.5% to £750,000; 10% to £1.5m; 12% above. Wales has no 2% band — it goes straight from 0% to 6% at £225,000.
First-time buyer reliefs
SDLT: 0% to £300,000, 5% from £300,001 to £500,000, no relief above £500,000.
LBTT: 0% to £175,000 (then standard bands).
LTT: no specific FTB relief — first-time buyers get the same £225,000 nil-rate band as everyone else, which is the most generous starting threshold in the UK.
Additional-dwelling surcharges
On a second residential property purchase, all three regimes add a surcharge on top of the standard rates: SDLT adds 5% (raised from 3% in October 2024); LBTT's Additional Dwelling Supplement is 8%; LTT adds 5%. So at the same price point, Scotland is the most expensive UK nation for buy-to-let investors and second-home buyers, by some margin.
Worked examples
£300,000 main residence (not first-time buyer). SDLT: £5,000. LBTT: £4,600. LTT: £4,500. Difference: Wales cheapest, England most expensive.
£300,000 first-time buyer. SDLT: £0 (within FTB relief). LBTT: £2,100 (full relief only goes to £175k, then standard bands). LTT: £4,500 (no FTB relief). England wins decisively for first-time buyers in this price range.
£500,000 main residence. SDLT: £15,000. LBTT: £23,350. LTT: £17,950. Scotland is significantly more expensive at this level because of its 10% band starting at £325k.
£750,000 main residence. SDLT: £27,500. LBTT: £48,350. LTT: £44,200. The Scotland penalty becomes pronounced.
£500,000 second home. SDLT: £40,000 (5% surcharge on £500k = £25,000, plus £15,000 standard). LBTT: £63,350. LTT: £42,950.
Which UK nation is cheapest?
It depends entirely on the purchase price and the buyer's status. For first-time buyers under £500,000, England (SDLT) is usually cheapest by some distance. For non-FTB main-residence buyers under £225,000, Wales is cheapest because of its high zero-rate threshold. For purchases over £325,000 or so, Scotland tends to be the most expensive nation, particularly at the top end. For second-home buyers, England is usually cheapest, Scotland costliest. Use our country-specific guides for the detail — Scotland LBTT and Wales LTT.
Filing and deadlines
All three regimes share a similar mechanic: file a return and pay the tax within a defined window after the effective date (usually completion). SDLT and LTT have a 14-day window. LBTT historically had 30 days but was tightened to 14 days for some transactions; check the current Revenue Scotland guidance. Your conveyancing solicitor handles the filing in practice. Late filing penalties apply across all three.
Refunds in each regime
Each regime has its own overpayment relief process. All three permit reclaim of the additional-dwelling surcharge when a previous main residence sells within a defined window. SDLT allows 4 years for general overpayment claims; LBTT and LTT have their own timeframes. If you bought outside England and think you overpaid, check the country-specific rules.
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