SDLT vs LBTT vs LTT: Stamp Duty Across the UK Compared
Buying a property in the UK? The amount of stamp duty you pay depends entirely on where in the UK you are buying. England, Scotland and Wales each run their own property transaction tax with different rates, thresholds and reliefs.
This guide compares all three systems side by side — Stamp Duty Land Tax (SDLT), Land and Buildings Transaction Tax (LBTT) and Land Transaction Tax (LTT) — so you can see exactly how they differ and which nation charges the most at every price point.
Why Are There Three Different Systems?
The UK does not have a single stamp duty system. Devolution gave Scotland and Wales the power to set their own property transaction taxes, replacing the UK-wide Stamp Duty Land Tax in those nations.
- SDLT (Stamp Duty Land Tax) — Applies in England and Northern Ireland, administered by HMRC. This is the original system that once covered the whole UK.
- LBTT (Land and Buildings Transaction Tax) — Applies in Scotland, administered by Revenue Scotland. Replaced SDLT in Scotland from 1 April 2015.
- LTT (Land Transaction Tax) — Applies in Wales, administered by the Welsh Revenue Authority (WRA). Replaced SDLT in Wales from 1 April 2018.
All three systems use a progressive, marginal rate structure — you pay each rate only on the portion of the price that falls within that band, not on the entire purchase price. However, the bands and rates vary significantly between them.
Standard Rates Compared: SDLT vs LBTT vs LTT
The table below shows the current standard residential rates for each system as of 2026/27.
| Price Band | SDLT (England & NI) | LBTT (Scotland) | LTT (Wales) |
|---|---|---|---|
| Up to £125,000 | 0% | 0% (up to £145k) | 0% (up to £225k) |
| £125,001 – £250,000 | 2% | 2% (£145k–£250k) | 0% (up to £225k) |
| £250,001 – £325,000 | 5% | 5% (£250k–£325k) | 6% (£225k–£400k) |
| £325,001 – £400,000 | 5% | 10% (£325k–£750k) | 6% (£225k–£400k) |
| £400,001 – £750,000 | 5% (up to £925k) | 10% (£325k–£750k) | 7.5% (£400k–£750k) |
| £750,001 – £925,000 | 5% (up to £925k) | 12% (over £750k) | 10% (£750k–£1.5m) |
| £925,001 – £1,500,000 | 10% | 12% | 10% |
| Over £1,500,000 | 12% | 12% | 12% |
Notice that Wales has the highest nil-rate threshold at £225,000, meaning buyers pay nothing on properties up to that price. Scotland's nil-rate band sits at £145,000, while England's is the lowest at just £125,000.
However, Scotland's rates jump sharply — hitting 10% from £325,000 compared to England where 10% does not kick in until £925,000. This makes Scotland significantly more expensive for mid-to-high value properties.
Which Nation Is Cheapest? Worked Examples
The best way to understand the real-world difference is to compare the actual tax bill at various price points. Here are four worked examples.
Property Price: £200,000
| Tax | Calculation | Total |
|---|---|---|
| SDLT | £0 on first £125k + 2% on £75k | £1,500 |
| LBTT | £0 on first £145k + 2% on £55k | £1,100 |
| LTT | £0 on first £225k | £0 |
Wales is cheapest. At £200,000 the property falls entirely within the Welsh nil-rate band, so there is zero tax to pay. Buyers in England pay £1,500 and in Scotland pay £1,100.
Property Price: £300,000
| Tax | Calculation | Total |
|---|---|---|
| SDLT | £0 on first £125k + 2% on £125k + 5% on £50k | £5,000 |
| LBTT | £0 on first £145k + 2% on £105k + 5% on £50k | £4,600 |
| LTT | £0 on first £225k + 6% on £75k | £4,500 |
Wales is cheapest. At £300,000 the gap narrows, but Wales still comes in lowest at £4,500. Scotland is close behind at £4,600, while England costs £5,000.
Property Price: £500,000
| Tax | Calculation | Total |
|---|---|---|
| SDLT | £0 on first £125k + 2% on £125k + 5% on £250k | £15,000 |
| LBTT | £0 on first £145k + 2% on £105k + 5% on £75k + 10% on £175k | £23,350 |
| LTT | £0 on first £225k + 6% on £175k + 7.5% on £100k | £18,000 |
England is cheapest. At £500,000, England (£15,000) beats Wales (£18,000); the two cost the same at £350,000 and England is cheaper above that. Scotland is the most expensive at £23,350 because its 10% band starts at just £325,000.
Property Price: £1,000,000
| Tax | Calculation | Total |
|---|---|---|
| SDLT | £0 on first £125k + 2% on £125k + 5% on £675k + 10% on £75k | £43,750 |
| LBTT | £0 on first £145k + 2% on £105k + 5% on £75k + 10% on £425k + 12% on £250k | £78,350 |
| LTT | £0 on first £225k + 6% on £175k + 7.5% on £350k + 10% on £250k | £61,750 |
England is cheapest. At the £1 million mark, SDLT's lower rates in the £250k–£925k band make England the most affordable. Scotland remains the most expensive by a wide margin at £78,350.
First-Time Buyer Relief: How Each Nation Helps
Each nation takes a different approach to helping first-time buyers onto the property ladder.
| Feature | SDLT (England & NI) | LBTT (Scotland) | LTT (Wales) |
|---|---|---|---|
| FTB relief available? | Yes | Yes | No |
| How it works | 0% on first £300k, 5% on £300k–£500k | Nil-rate band raised to £175k | No specific relief |
| Maximum property price | £500,000 | No cap | N/A |
| Maximum saving | £5,000 | £600 | £0 |
England offers the most generous first-time buyer relief, with a saving of up to £5,000 on properties up to £500,000. Scotland's relief is more modest — raising the nil-rate threshold by £30,000 from £145,000 to £175,000, saving a maximum of £600.
Wales offers no first-time buyer relief at all. However, Wales compensates with its higher nil-rate band of £225,000, which benefits all buyers regardless of whether they are purchasing their first property.
Additional Property Surcharges Compared
Buying a second home, buy-to-let or additional property triggers a surcharge in all three nations — but the way it is calculated differs significantly.
| Feature | SDLT (England & NI) | LBTT (Scotland) | LTT (Wales) |
|---|---|---|---|
| Surcharge rate | +5% on each band | 8% ADS on full price | Separate higher-rate bands |
| How it's applied | Marginal (added to each band) | On the entire purchase price | Marginal (separate rate table) |
| Example at £300,000 | £5,000 + £15,000 = £20,000 | £4,600 + £24,000 = £28,600 | Higher-rate table applies |
Scotland's Additional Dwelling Supplement (ADS) is by far the most punishing. At 8%, it is charged on the entire purchase price — not just the portion above a threshold. On a £300,000 second home in Scotland, the ADS alone adds £24,000 on top of the standard LBTT.
England's 5% surcharge is added marginally to each band, making it less severe in comparison. Wales uses a completely separate set of higher-rate bands for additional properties.
Key Differences at a Glance
| Feature | SDLT (England & NI) | LBTT (Scotland) | LTT (Wales) |
|---|---|---|---|
| Nil-rate band | £125,000 | £145,000 | £225,000 |
| First-time buyer relief | Yes (up to £5,000) | Yes (up to £600) | No |
| Additional property | +5% marginal surcharge | 8% ADS on full price | Separate higher-rate bands |
| 10% rate starts at | £925,001 | £325,001 | £750,001 |
| Administering body | HMRC | Revenue Scotland | Welsh Revenue Authority |
| In effect since | 2003 | April 2015 | April 2018 |
Which System Is Best for Buyers?
There is no single "cheapest" system — it depends on the property price, buyer status and whether it is an additional property.
- For properties under £225,000 — Wales is cheapest (zero tax). Scotland is second, England is most expensive.
- For properties £225,000 to £350,000 — Wales is usually cheapest. Scotland is narrowly cheapest between about £310,000 and £329,000; England and Wales tie at £350,000.
- For properties above £350,000 — England is cheapest at every price, because its 5% band runs all the way to £925,000.
- For first-time buyers — England offers the best relief. Wales has no relief but a high nil-rate band. Scotland's relief is minimal.
- For additional properties — Avoid Scotland if possible. The 8% ADS on the full price is substantially more expensive than the surcharges in England or Wales.
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