LBTT vs SDLT 2026: Scotland vs England Compared
Scotland charges Land and Buildings Transaction Tax (LBTT) collected by Revenue Scotland. England and Northern Ireland charge Stamp Duty Land Tax (SDLT) collected by HMRC. The bands, the surcharge structure, and even the first-time buyer relief differ between the two regimes.
Bands side-by-side (standard buyer)
| England + NI (SDLT) | SDLT rate | Scotland (LBTT) | LBTT rate |
|---|---|---|---|
| £0 to £125,000 | 0% | £0 to £145,000 | 0% |
| £125,001 to £250,000 | 2% | £145,001 to £250,000 | 2% |
| £250,001 to £925,000 | 5% | £250,001 to £325,000 | 5% |
| £925,001 to £1,500,000 | 10% | £325,001 to £750,000 | 10% |
| Above £1,500,000 | 12% | Above £750,000 | 12% |
The 10% LBTT band kicks in at £325,000 in Scotland vs £925,000 in England. That single threshold difference is the main reason Scotland costs more at mid and higher prices.
Worked examples (standard buyer)
| Price | England SDLT | Scotland LBTT | Difference |
|---|---|---|---|
| £150,000 | £500 | £100 | Scotland -£400 |
| £250,000 | £2,500 | £2,100 | Scotland -£400 |
| £300,000 | £5,000 | £4,600 | Scotland -£400 |
| £400,000 | £10,000 | £13,350 | Scotland +£3,350 |
| £500,000 | £15,000 | £23,350 | Scotland +£8,350 |
| £750,000 | £27,500 | £48,350 | Scotland +£20,850 |
| £1,000,000 | £43,750 | £78,350 | Scotland +£34,600 |
Crossover point is around £330,000-£340,000. Below this, Scotland is cheaper by ~£400 because of the higher nil-rate band. Above, Scotland pulls steeply ahead because the 10% LBTT band starts at £325,000 vs SDLT's £925,000.
ADS vs the 5% surcharge: structural difference
For additional properties, the structural difference between the two regimes matters more than the headline rates.
| Price | England (standard + 5%) | Scotland (LBTT + ADS 8%) | Difference |
|---|---|---|---|
| £200,000 | £11,500 | £17,100 | +£5,600 |
| £300,000 | £20,000 | £28,600 | +£8,600 |
| £500,000 | £40,000 | £63,350 | +£23,350 |
| £1,000,000 | £93,750 | £158,350 | +£64,600 |
First-time buyer relief: England vs Scotland
England's FTB relief is structurally generous but cliff-edged: 0% up to £300,000, 5% on £300,000 to £500,000, lost entirely above £500,000. Maximum FTB saving in England is £6,250 (the £6,250 difference between £15,000 standard and £8,750 FTB at the £500,000 cap).
Scotland's FTB relief is more modest: the FTB nil-rate band is £175,000 (rather than £145,000), saving a maximum of £600 in LBTT. There is no cliff edge - the £600 relief applies at every price above the threshold, all the way up.
At low prices (£175,000 to £300,000), England's FTB relief tends to be much more valuable than Scotland's. At higher prices England's FTB cliff and Scotland's modest relief converge, and above the £500,000 cliff Scotland's FTB-eligible buyer still gets £600 off while England's loses everything.
Frequently Asked Questions
Is stamp duty higher in Scotland or England?
Below ~£330,000, Scotland is cheaper (~£400 less) because of the higher £145,000 nil-rate band. Above ~£330,000, Scotland is increasingly more expensive because the LBTT 10% band starts at £325,000 (vs SDLT 10% at £925,000). At £1m, Scotland costs £34,600 more than England.
Is the additional property surcharge higher in Scotland?
Yes. Scotland's ADS is 8% on the full purchase price (not marginal). England's surcharge is 5% applied marginally. The structural difference makes Scotland materially more expensive for additional properties at every price. At £300,000: Scotland costs £8,600 more; at £1m: £64,600 more.