February 2, 2026
SDLT, LTT and LBTT
If you are considering buying a residential property in England valued at £2 million or more, it is important to understand the new High Value Council Tax Surcharge (HVCTS), often described as a “mansion tax”, announced in the UK Government’s Budget on 26 November 2025.
This new annual charge sits alongside existing Stamp Duty Land Tax (SDLT) rules, which already impose higher rates for additional properties and overseas buyers. Together, they materially change the long-term cost profile of owning high-value UK residential property.
For many years, the UK has stood apart from much of Europe by not imposing an annual tax linked directly to property value beyond standard council tax. Although a “mansion tax” has been discussed for decades, it never took shape until now.
The HVCTS is more modest than many anticipated, but it will still affect owners of high-value homes and should be factored into acquisition and holding decisions.
The surcharge applies to residential properties valued at £2 million or more, with four bands:
£2.0m–£2.5m: £2,500 per year
£2.5m–£3.5m: £3,500 per year
£3.5m–£5.0m: £5,000 per year
£5m+: £7,500 per year
The charge will increase annually in line with the Consumer Prices Index, and properties will be revalued every five years by the Valuation Office.
The HVCTS is payable in addition to council tax and SDLT, including any non-resident surcharge. Where a property is let, the surcharge is payable by the owner rather than the tenant. For buy-to-let investors, this recurring cost may affect net yields and should be reflected in long-term financial modelling.
Owners may also wish to review existing ownership and financing structures in light of this ongoing charge.
SDLT is charged on the purchase price of property in England. After years of temporary bands and reliefs, the current regime represents a return to a more settled framework, albeit one with significant complexity for higher-value and overseas buyers.
For residential purchases, SDLT rates can be increased where the buyer owns another property anywhere in the world, or the buyer is not UK-resident for SDLT purposes.
At the highest level, residential SDLT can reach 12%, with a further 5% surcharge for additional homes and 2% for non-UK residents.
Lower SDLT rates can apply where a property includes a genuine non-residential element, such as agricultural land or business premises. These mixed-use rates can reduce SDLT significantly, but the rules are complex and highly fact-specific.
For residential property, the 2% non-resident surcharge applies if the buyer has spent at least six of the 12 months before purchase outside the UK.
This surcharge may be refunded if the buyer later becomes UK-resident and meets the relevant conditions. The 5% additional home surcharge may also be refunded if a buyer sells their former main residence within three years.
Where a non-UK company or non-UK discretionary trust acquires a residential property worth more than £500,000 and the property is not let to an unconnected third party, a flat SDLT rate of 17% can apply, plus the 2% non-resident surcharge, giving an effective rate of 19%. Certain UK companies controlled by non-UK residents can also fall within this regime.
The HVCTS will not come into force until 6 April 2028, allowing time for consultation and for high-value properties to be revalued. Where a property sits close to a valuation threshold, it may be possible to challenge the assessed value.
Although modest by international standards, the HVCTS signals a clear shift in the UK’s approach to taxing high-value residential property. Combined with SDLT and other potential taxes, it reinforces the importance of forward planning.
Overseas investors should review existing holdings, factor the full tax position into purchasing budgets and take professional advice on valuations and ownership structures before proceeding.
In the meantime, why not view our SDLT for Non-UK Residents page here.
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