Homes for Ukraine: when it does not stop 17% SDLT business relief
Homes for Ukraine and 17% SDLT
HMRC says that housing eligible people through Homes for Ukraine does not by itself stop a company claiming the relevant business relief from the 17% SDLT charge.
- The normal business-relief test still applies.
- The transaction must have an effective date on or after 31 March 2022.
- A non-qualifying individual living in the home can prevent relief.
Scroll down for the full analysis.
Read the original guidance here:
Homes for Ukraine: when it does not stop 17% SDLT business relief
Homes for Ukraine: when it does not stop 17% SDLT business relief
If a company buys a high-value home for a qualifying business reason, hosting eligible Homes for Ukraine guests need not stop its stamp duty relief. HMRC ignores that plan. Non-qualifying occupants block the relief.
What this rule is about
This is not the extra stamp duty on a second home. Instead, it concerns a separate 17% SDLT charge that can apply when a company or similar body buys a single home above the higher-value threshold.
Some genuine property businesses can claim relief from that charge. For example, the law allows relief for specified commercial rental, development, redevelopment and property trading activities. A company must buy the home only for one or more of those business purposes.
That sounds narrow. It is meant to stop a company using a business relief for a home that is really for its owners or people close to them.
What the official source says
HMRC’s manual says that, where the business purpose existed on the date that counts for SDLT, the transaction otherwise qualifies for the relief, and the accommodation plan is under the scheme, a Homes for Ukraine arrangement alone does not spoil this relief. HMRC disregards the plan. The treatment also applies where a plan, made then or later, is to house people under the scheme.
- The transaction must have its effective date on or after 31 March 2022.
- The home must otherwise qualify for the business relief in Schedule 4A paragraph 5.
- The plan to provide accommodation must be under the Homes for Ukraine Sponsorship Scheme.
- HMRC says that the same treatment also covers a person who, after being accommodated under the scheme, later moves to the Ukraine Permission Extension scheme.
- The person allowed to live there must not be a non-qualifying individual.
- HMRC says relief does not apply where a non-qualifying individual is allowed to occupy the home.
What this means in practice
A company does not have to choose between a qualifying business use and helping through the scheme, because, when deciding whether business relief was available at the start, HMRC disregards the additional plan to accommodate an eligible guest. Timing matters.
Completion is usually the effective date, although SDLT rules can produce a different date in some cases.
- Keep proof of the business plan that existed when the home was bought.
- Keep records showing that the accommodation was offered through the scheme.
- Check who actually had permission to live in the home.
- Do not assume that any charitable aim creates the SDLT relief.
- Read the separate HMRC guidance on what can happen if relief is later withdrawn.
How to analyse it
Start with the basic tax rule, not the sponsorship plan. Would Schedule 4A relief apply without it?
- Check whether the 17% charge is in point for the purchase.
- Identify the company’s stated business use for the home.
- Test that use against one of the business purposes listed in Schedule 4A paragraph 5.
- Fix the SDLT effective date and check that it was on or after 31 March 2022.
- Identify each person whom the company intended to house under the scheme.
- Check whether any proposed occupant falls within the statutory non-qualifying definition.
- Separate the scheme guest from any other person allowed to live there.
Example
Bright Lets Ltd buys a home for £750,000 on 8 April 2022. Its records show a commercial rental plan that would otherwise meet the business relief conditions.
At the same time, it plans accommodation. That accommodation is for an eligible Homes for Ukraine guest. HMRC ignores that extra plan for this relief. Relief could change if the company also lets a non-qualifying individual live there.
Why this can be difficult in practice
This is the part people get wrong: the scheme does not replace the normal business-relief test. HMRC treats that accommodation plan differently. Only that test uses this treatment.
Applying the non-qualifying rule can also be difficult. The legislation uses a detailed definition that includes certain connected people, relatives and people linked with the company or relevant arrangement. A guest’s visa status alone does not answer every question.
- Even where the reason for buying the home is a good one, it is not enough unless it was a listed business purpose.
- A later change in who lives there may need separate consideration.
- Calling someone a guest does not decide whether they are non-qualifying.
- The HMRC manual does not set out every consequence of relief being withdrawn.
Key takeaways
- Homes for Ukraine guests need not stop the business relief, on HMRC’s view.
- The underlying business-relief conditions still have to be met.
- Occupation by a non-qualifying individual can prevent relief.
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 Schedule 4A para 1 — when a home interest exceeds the higher threshold
- FA 2003 Schedule 4A para 3 — the 17% charge for certain company purchases
- FA 2003 Schedule 4A para 5 — business relief from the 17% charge
- FA 2003 Schedule 4A para 5A — people treated as non-qualifying individuals
- FA 2003 section 119 — what counts as the transaction effective date
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
- The statutory text supplied does not itself mention the Homes for Ukraine Sponsorship Scheme or the Ukraine Permission Extension scheme.
- The source does not give the full facts needed to decide whether a particular guest is a non-qualifying individual.
- The source directs readers to a separate HMRC manual page for the effect of later events on relief, rather than setting out that detail here.
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 purchase date that counts for SDLT.
- Documents showing the company’s business purpose when it bought the home.
- Records of any Homes for Ukraine arrangement and who was allowed to live there.
- Evidence needed to check whether any occupant falls within the statutory non-qualifying definition.
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 Homes for Ukraine: when it does not stop 17% SDLT business relief [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 Schedule 4A para 1 - when a home interest exceeds the higher threshold https://www.legislation.gov.uk/ukpga/2003/14/schedule/4A/paragraph/1/2025-11-17 - FA 2003 Schedule 4A para 3 - the 17% charge for certain company purchases https://www.legislation.gov.uk/ukpga/2003/14/schedule/4A/paragraph/3/2025-11-17 - FA 2003 Schedule 4A para 5 - business relief from the 17% charge https://www.legislation.gov.uk/ukpga/2003/14/schedule/4A/paragraph/5/2025-11-17 - FA 2003 Schedule 4A para 5A - people treated as non-qualifying individuals https://www.legislation.gov.uk/ukpga/2003/14/schedule/4A/paragraph/5A/2025-11-17 - FA 2003 section 119 - what counts as the transaction effective date https://www.legislation.gov.uk/ukpga/2003/14/section/119/2025-11-17 Guidance page from HMRC on this topic (guidance, not law): https://www.gov.uk/hmrc-internal-manuals/stamp-duty-land-tax-manual/sdltm09652 HOW I WANT YOU TO ANSWER 1. Work from the legislation above. Read it before answering. Guidance from HMRC is its 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 - The statutory text supplied does not itself mention the Homes for Ukraine Sponsorship Scheme or the Ukraine Permission Extension scheme. - The source does not give the full facts needed to decide whether a particular guest is a non-qualifying individual. - The source directs readers to a separate HMRC manual page for the effect of later events on relief, rather than setting out that detail here. 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 31 August 2026
Useful article? You may find it helpful to read the original guidance here: Homes for Ukraine: when it does not stop 17% SDLT business relief
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