Stamp Duty Relief for Homes for Ukraine Sponsorship Scheme Explained

SDLT 17% Higher Rate Relief and Homes for Ukraine Occupation

HMRC says that a company or other non-natural person may still get relief from the 17% SDLT higher rate on a residential property if, at the effective date of purchase, the property was acquired only for a qualifying purpose under Schedule 4A. Letting someone live there under the Homes for Ukraine Sponsorship Scheme does not by itself block that relief, provided the occupier is not a non-qualifying individual and the transaction’s effective date is on or after 31 March 2022.

• The rule applies to certain companies and other non-natural persons buying dwellings that could otherwise face the 17% SDLT rate.
• Relief depends first on the property being bought exclusively for one or more qualifying purposes in paragraph 5 of Schedule 4A at the effective date.
• If that qualifying intention existed at the effective date, a later or additional intention to house someone under the Homes for Ukraine Sponsorship Scheme is ignored.
• This treatment also covers cases where the occupier later moves from the Homes for Ukraine visa route to the Ukraine Permission Extension scheme.
• Relief is not available on this basis if the property is occupied by a non-qualifying individual.
• The main practical checks are the buyer’s status, whether the property is a dwelling, the effective date, and whether relief could later be withdrawn under separate rules.

Scroll down for the full analysis.

SDLT 17% higher rate relief and the Homes for Ukraine Sponsorship Scheme

This page explains a narrow but important SDLT point for companies and other non-natural persons that buy residential property. It deals with when occupation under the Homes for Ukraine Sponsorship Scheme does not prevent relief from the 17% higher rate of SDLT.

What this rule is about

Residential property bought by certain non-natural persons can be charged to SDLT at a 17% rate. This is a special higher rate that applies in defined cases. However, relief may be available if the dwelling is acquired exclusively for one or more of the purposes listed in paragraph 5 of Schedule 4A to Finance Act 2003.

One practical concern is what happens if, after buying the property for a qualifying purpose, the buyer also wants to let someone live there under the Homes for Ukraine Sponsorship Scheme. Without a specific rule, that occupation might cast doubt on whether the property was being used only for a qualifying purpose.

What the official source says

HMRC says that relief from the 17% higher rate is ordinarily available where, at the effective date of the transaction, the dwelling is acquired exclusively for one or more of the qualifying purposes in paragraph 5 of Schedule 4A.

Where that intention exists at the effective date, any additional or later intention to allow occupation under the Homes for Ukraine Sponsorship Scheme is ignored, provided the occupier is not a non-qualifying individual.

HMRC also states that this treatment includes cases where a person who originally came under the Homes for Ukraine Sponsorship visa scheme later moves onto the Ukraine Permission Extension scheme.

The relief does not apply if the property is allowed to be occupied by a non-qualifying individual.

This change applies to land transactions with an effective date on or after 31 March 2022.

What this means in practice

The key point is that occupation under the Homes for Ukraine Sponsorship Scheme does not, by itself, stop relief from being available, as long as the statutory conditions are otherwise met.

The timing matters. The buyer must have the required qualifying intention at the effective date of the transaction. If that is in place, a further intention, or a later decision, to house someone under the Scheme is disregarded for this purpose.

In practical terms, this means a company or other relevant non-natural person may still be able to claim relief from the 17% rate even if the property is used to accommodate a person under the Scheme, so long as:

• the original acquisition was exclusively for one or more qualifying purposes under paragraph 5 of Schedule 4A, and
• the person allowed to occupy is not a non-qualifying individual.

The source does not restate the full meaning of “non-qualifying individual”, so that term must be understood by reference to the wider Schedule 4A rules.

How to analyse it

A sensible way to approach this issue is to ask the following questions.

• Is the buyer a person to whom the 17% higher rate rules can apply, such as a company or other non-natural person within Schedule 4A?
• Is the property a dwelling for the purposes of those rules?
• At the effective date of the transaction, was the dwelling acquired exclusively for one or more of the qualifying purposes in paragraph 5 of Schedule 4A?
• Is the proposed occupation connected with the Homes for Ukraine Sponsorship Scheme?
• Is the occupier a non-qualifying individual? If yes, the relief does not apply on the basis described in this HMRC material.
• If the occupier first came under the Homes for Ukraine Sponsorship visa route and later moved onto the Ukraine Permission Extension scheme, does the case still fall within the treatment described by HMRC? HMRC says yes.
• What is the effective date of the transaction? The change only applies on or after 31 March 2022.

This rule does not create a free-standing relief for all accommodation provided under the Scheme. It operates within the existing relief from the 17% higher rate. The starting point is still whether the acquisition meets one of the qualifying purposes in paragraph 5.

Example

A company buys a dwelling on 1 April 2022 and, at the effective date, intends to hold it exclusively for a qualifying purpose under paragraph 5 of Schedule 4A. Later, the company agrees to let a Ukrainian individual occupy the property under the Homes for Ukraine Sponsorship Scheme. On the basis of the HMRC material, that additional or later intention is ignored when considering relief from the 17% higher rate, provided the occupier is not a non-qualifying individual.

If instead the property is allowed to be occupied by a non-qualifying individual, the relief would not apply on the basis stated in this guidance.

Why this can be difficult in practice

The most sensitive issue is often not the Scheme itself, but whether the acquisition was genuinely made exclusively for a qualifying paragraph 5 purpose at the effective date. That is a factual question.

Another difficulty is the term “non-qualifying individual”. This page assumes the reader will look to the wider Schedule 4A framework for that definition. In practice, that means you cannot decide the issue from this page alone.

There is also a distinction between claiming relief in the first place and keeping it. HMRC’s page refers separately to the interaction between the Scheme and withdrawal of relief. So even where relief is initially available, later events may still need to be checked under the withdrawal rules.

Key takeaways

• Occupation under the Homes for Ukraine Sponsorship Scheme does not automatically prevent relief from the SDLT 17% higher rate.
• The buyer must still satisfy the ordinary Schedule 4A relief conditions, including having the required qualifying intention at the effective date.
• The protection does not apply if the property is allowed to be occupied by a non-qualifying individual.

This page was last updated on 24 March 2026

Useful article? You may find it helpful to read the original guidance here: Stamp Duty Relief for Homes for Ukraine Sponsorship Scheme Explained

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