October 30, 2026
SDLT, LTT and LBTT
Property taxation featured prominently in the Autumn Budget, with changes affecting landlords, investors, developers and those involved in more complex property transactions.
Perhaps the most immediately relevant change for individual property investors is the increase in tax on property income. From April 2027, the rates will rise to 24%, 44% and 49%, adding further pressure to the cost of holding investment property personally.
For landlords and investors, this may prompt a wider review of how property is held. However, changing an existing ownership structure can itself give rise to significant tax consequences, particularly for Capital Gains Tax and Stamp Duty Land Tax (SDLT), so the overall position needs to be considered carefully.
The Budget also closes an SDLT group relief loophole with effect from 29 October 2026.
The change concerns transactions where property is transferred within a corporate group before the company receiving the property is subsequently sold. The new rules prevent the clawback of group relief from being avoided by winding up the original transferor within the relevant three-year period.
This is a relatively targeted change, but an important reminder that corporate property transactions and restructurings can carry complex SDLT consequences which may not always be apparent at the outset.
Despite speculation ahead of the Budget, there was no further enhancement to SDLT relief for first-time buyers. The existing relief therefore remains in place, alongside the new savings and equity-loan measures announced for those looking to purchase their first home.
At the other end of the market, the threshold for the High Value Council Tax Surcharge remains at £2 million, with the new charge due to apply from April 2028.
Taken together, the announcements continue a broader trend towards increasingly complex taxation of property ownership and transactions.
At BHP, SDLT is one of our core areas of expertise. We regularly advise on complex property transactions, corporate and partnership structures, reliefs and the interaction between SDLT and other taxes. Where a transaction falls outside the straightforward purchase of a property, taking specialist advice at an early stage can help identify the tax position before arrangements become difficult to unwind.
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