July 29, 2026
SDLT
Amanda Perrotton
When purchasing a residential property, it’s sometimes possible to reduce the amount of Stamp Duty Land Tax (SDLT) payable by separately identifying the value of certain fixtures and fittings included in the sale.
Done correctly, this is a perfectly legitimate form of tax planning. Done incorrectly, it can result in HMRC enquiries, additional tax, penalties and interest.
The key is understanding what qualifies as a chattel, how those items should be valued and why the evidence behind the figures is so important.
Not everything included in a property sale is treated the same for SDLT purposes.
Fixtures form part of the property itself and remain subject to SDLT. These are items that are fixed to the building and would generally cause damage if removed. Examples include fitted kitchens, integrated appliances, bathroom suites and central heating systems.
Chattels, on the other hand, are moveable items that retain their identity when removed. These can include carpets, curtains, freestanding furniture, artwork and certain white goods.
Only the amount paid for the property and its fixtures is subject to SDLT. The value of genuine chattels falls outside the scope of the tax.
A common misconception is that the buyer and seller can simply agree how much of the purchase price relates to the contents.
Unfortunately, it isn’t that straightforward.
The law requires any apportionment between the property and the chattels to be just and reasonable. Simply agreeing a figure in the contract doesn’t make it correct if it doesn’t reflect the true market value of the items being sold.
This is where many transactions fall down.
The value attributed to chattels should reflect what those items are genuinely worth on the date of completion, taking into account their age, condition and depreciation. In most cases, this will be significantly less than the price originally paid for them.
Where the value of the contents is substantial, obtaining a valuation from a suitably qualified valuer may be worthwhile.
It’s also sensible to prepare a detailed contents schedule identifying each item being sold, together with its condition and an individual value. Supporting photographs can also be helpful, particularly if HMRC later asks questions.
SDLT is a self-assessed tax, meaning the buyer is ultimately responsible for ensuring the return is accurate.
If HMRC believes that fixtures have been incorrectly treated as chattels, or that the values appear excessive, it can open an enquiry into the SDLT return. These enquiries are often supported by the Valuation Office Agency, which may request a detailed schedule of the items together with evidence supporting the values used.
Without appropriate records, defending the position can quickly become difficult and expensive.
If you’re considering a chattel apportionment, it’s worth remembering a few key principles:
A properly supported chattel apportionment can legitimately reduce the amount of SDLT payable on a property purchase. However, it’s an area that HMRC scrutinises closely, so accuracy and evidence are essential.
At BHP, we regularly advise buyers, sellers and their solicitors on SDLT planning opportunities, helping ensure transactions are structured correctly while remaining fully compliant with HMRC’s requirements. Obtaining specialist advice before contracts are exchanged can help you maximise available reliefs and avoid costly mistakes.
