17% stamp duty when a company buys a high-value home
The short answer
A company or similar buyer may pay SDLT at 17% on the full price of a high-value home. The key threshold is more than £500,000, but the buyer type and statutory exceptions also matter.
- This is not the ordinary second-home surcharge.
- Linked purchases of interests in the same home can be added together.
- Historic transactions may be subject to different thresholds or transition rules.
Scroll down for the full analysis.
Read the original guidance here:
17% stamp duty when a company buys a high-value home
A company buying a home for more than £500,000 can face stamp duty at 17% of the full amount paid. This is not the extra rate for a second home. It is a separate, much higher rule for certain company and investment buyers.
What this rule is about
Most stamp duty is worked out in bands. This rule works differently. Where the rule applies, once the relevant interest is in a home, the amount paid is above £500,000, and the buyer meets the statutory conditions, the 17% rate applies to the whole amount paid. There is no banding.
Certain non-individual buyers of high-value residential property are the target of the rule. In everyday terms, that mainly means a company, although some partnerships and collective investment schemes can also fall within the test.
That distinction matters. For the threshold to be crossed, more than £500,000 must be paid, while both the buyer and property must also satisfy the remaining parts of the test. Price alone is insufficient.
What the official source says
HMRC’s manual says the special rate applies in certain cases where a higher-threshold interest in residential property is bought. More than £500,000 is the current threshold. At present, the rate is 17%.
For the core test, the legislation sets out the relevant conditions. It applies where the deal is for a high-value home interest and the buyer condition is met.
- The interest in one home must have more than £500,000 attributed to it.
- The deal can include a home with its garden, grounds and rights that go with it.
- The buyer can be a company, unless it is a public body.
- A partnership can fall within the test where one or more members is a company that is not a public body.
- The test can cover a purchase for a collective investment scheme.
- A company acting as trustee of a settlement is excluded from the company part of this test.
- If joint buyers include one that meets the test, the buyer condition can be met.
HMRC’s page says the rate was 15% before it increased to 17% on 31 October 2024. It also records historic thresholds. From 21 March 2012 to before 20 March 2014, the threshold was £2 million. From 20 March 2014, it was £500,000.
What this means in practice
Do not assume that putting a home into a company only changes the usual stamp duty bands. It can trigger this separate rate instead.
The £500,000 test is strict. A purchase at exactly £500,000 does not pass the statutory test for a higher-threshold interest. A purchase for £500,001 can do so, if the other conditions are met.
- Check the legal buyer before contracts are exchanged.
- Check whether a trust arrangement changes who counts as the buyer.
- Check whether a partnership has a company member.
- Review any related deals for interests in the same home.
- Keep evidence of the intended business use if an exception may apply.
How to analyse it
Start with the deal, not the label used for it. Calling a purchase an investment or a business purchase does not settle the answer.
- Find the effective date: this decides which historic rate and threshold may apply.
- Work out whether the property includes one home for this rule.
- Identify the amount paid that relates to that home.
- Ask whether that amount is more than £500,000.
- Identify the real buyer: company, partnership, scheme, trustee or public body.
- Check for linked purchases of interests in the same home.
- Consider whether a specific business exception applies.
- Check whether an old contract or partnership transition rule changes the result.
This is the part people can miss: two linked purchases of interests in the same home may be added together for the £500,000 test. Splitting the purchase into separate documents does not necessarily keep it below the threshold.
Example
Illustration: Oak Ltd buys a house for £600,000. Assume the house is one home for this rule, Oak Ltd is not a public body or trustee, and no business exception applies. The amount is more than £500,000, so the 17% rate applies to the full £600,000. The SDLT under this special rule is £102,000.
Change one fact. Where Oak Ltd pays exactly £500,000 for the relevant interest, the statutory wording requires more than that amount, so it does not meet the “more than £500,000” threshold. The line is exact. That does not mean no SDLT is due. It means this particular 17% rule does not apply on that fact alone.
Why this can be difficult in practice
In practice, easy-to-overlook details can decide the result. A home with land, several related contracts, a trust, or a partnership can make the analysis more complex.
There are also statutory exceptions. For example, the legislation has exceptions for certain qualifying property rental, property trading and property development activities. Those rules are detailed. The intended use and proposed occupation can matter.
- A company purchase is not automatically subject to the 17% rate.
- A business purpose is not automatically an exception.
- The price of a wider mixed purchase may need a fair split.
- Linked purchases can change the threshold result.
- Older deals may be affected by special transition rules.
- HMRC’s manual is guidance, not the law itself.
Key takeaways
- The 17% rule is separate from the extra rate for a second home.
- It can apply when certain non-individual buyers pay more than £500,000 for one home interest.
- The buyer type, linked deals and any business exception all need checking.
Technical analysis
For advisers, and for anyone who wants to check the law behind this page. You do not need this section to understand the guidance above.
Legislation
- FA 2003 section 55A — schedule 4a sets the special tax calculation
- FA 2003 Schedule 4A para 1 — the £500,000 test for a single home
- FA 2003 Schedule 4A para 2 — how high-value home interests are identified and split
- FA 2003 Schedule 4A para 3 — the 17% rate and buyers it covers
- FA 2003 Schedule 4A para 4 — linked purchases of interests in the same home
- FA 2003 Schedule 4A para 5 — business uses that can prevent the special rate
- FA 2003 section 74 — relief for tenants exercising collective flat ownership rights
Official guidance
The pages below are HMRC’s guidance. Guidance is not law. It sets out how HMRC reads the legislation, and it is not binding on you, on a tribunal or on a court. Where guidance and the legislation differ, the legislation wins. HMRC can also change or withdraw guidance, and it may not cover your facts.
Where this is not settled
- Whether a business exception applies can depend on the intended use of the property and who may occupy it.
- The treatment of an older contract or a partnership arrangement may depend on transitional rules not explained on this source page.
- The correct result for a mixed purchase can depend on how the amount paid is fairly allocated between the home and other land.
Evidence you would need
This kind of case is decided on the facts of the individual property. These are the records that usually settle it, and the ones an adviser would ask you for.
- The effective date of the transaction.
- The contract and completion documents.
- The buyer’s legal form and any trust or partnership documents.
- Details of all linked purchases involving the same home.
- A breakdown of the amount paid where the purchase includes other land.
- Business plans and occupation evidence where an exception is claimed.
Explore this with an AI
Readers often want to test their own situation. Copy the prompt below into ChatGPT, Claude or Gemini. It hands the model the actual legislation for this page rather than letting it answer from memory, and tells it to be explicit about what is uncertain. What comes back is information, not advice – check it against the links above.
I am researching UK Stamp Duty Land Tax (SDLT), which applies in England and Northern Ireland. MY QUESTION 17% stamp duty when a company buys a high-value home [Replace this with your own situation: what you are buying, the price, the dates, who the buyer is, and what you plan to do with the property.] THE LAW THIS TURNS ON - FA 2003 section 55A - schedule 4a sets the special tax calculation https://www.legislation.gov.uk/ukpga/2003/14/section/55A/2025-11-17 - FA 2003 Schedule 4A para 1 - the £500,000 test for a single home https://www.legislation.gov.uk/ukpga/2003/14/schedule/4A/paragraph/1/2025-11-17 - FA 2003 Schedule 4A para 2 - how high-value home interests are identified and split https://www.legislation.gov.uk/ukpga/2003/14/schedule/4A/paragraph/2/2025-11-17 - FA 2003 Schedule 4A para 3 - the 17% rate and buyers it covers https://www.legislation.gov.uk/ukpga/2003/14/schedule/4A/paragraph/3/2025-11-17 - FA 2003 Schedule 4A para 4 - linked purchases of interests in the same home https://www.legislation.gov.uk/ukpga/2003/14/schedule/4A/paragraph/4/2025-11-17 - FA 2003 Schedule 4A para 5 - business uses that can prevent the special rate https://www.legislation.gov.uk/ukpga/2003/14/schedule/4A/paragraph/5/2025-11-17 - FA 2003 section 74 - relief for tenants exercising collective flat ownership rights https://www.legislation.gov.uk/ukpga/2003/14/section/74/2025-11-17 HMRC's guidance page on this topic (guidance, not law): https://www.gov.uk/hmrc-internal-manuals/stamp-duty-land-tax-manual/sdltm09505 HOW I WANT YOU TO ANSWER 1. Work from the legislation above. Read it before answering. HMRC guidance is HMRC's view of the law, not the law, and does not bind a tribunal or a court. 2. Tell me what the rule actually requires, in plain English. 3. Tell me which facts decide the answer, and which facts would change it. 4. Tell me what evidence I would need to support the position. 5. Be explicit about anything unsettled or fact-sensitive. Do not guess. 6. Your training data has a cutoff and SDLT rates and reliefs change at fiscal events. Say so if you are not sure the law is current. POINTS ALREADY KNOWN TO BE UNCERTAIN ON THIS TOPIC - Whether a business exception applies can depend on the intended use of the property and who may occupy it. - The treatment of an older contract or a partnership arrangement may depend on transitional rules not explained on this source page. - The correct result for a mixed purchase can depend on how the amount paid is fairly allocated between the home and other land. Do not give me a conclusion you cannot support from the provisions above.
Legislation links show Finance Act 2003 as it stood on 2025-11-17. The law may have changed since, and the rules that apply are those in force on the date of your transaction. The official guidance this page is based on is here.
This page was last updated on 1 September 2026
Useful article? You may find it helpful to read the original guidance here: 17% stamp duty when a company buys a high-value home
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