Homes for Ukraine hosting and SDLT relief for company-owned homes
Homes for Ukraine and SDLT relief
HMRC says that use of a home for the Homes for Ukraine Sponsorship Scheme may not cause paragraph 5 SDLT relief to be withdrawn.
- The buyer must act without undue delay.
- Scheme registration alone is not enough.
- The statutory basis should be checked against current law.
Scroll down for the full analysis.
Read the original guidance here:
Homes for Ukraine hosting and SDLT relief for company-owned homes
Homes for Ukraine hosting and SDLT relief for company-owned homes
A company that has claimed stamp duty relief for a home bought for its business may not lose that relief by hosting people through Homes for Ukraine.
However, HMRC says that joining the scheme alone is insufficient. The company must take real steps to provide a home without undue delay.
What this rule is about
This rule concerns a narrow form of special SDLT relief. It may apply where a high-value home is bought solely for certain business uses, including letting, property development or property trading.
Usually, the relief must remain under review for three years after purchase. A change in the home’s use can result in the relief being withdrawn.
What the official source says
HMRC’s manual says that a home continues to be held for the required business purpose when it is used for the Homes for Ukraine Sponsorship Scheme.
In HMRC’s view, that use does not trigger withdrawal of the relief under paragraph 5G.
- People placed under the Homes for Ukraine Sponsorship Scheme may occupy the home.
- This includes people who later move onto the Ukraine Permission Extension visa scheme.
- The protection does not apply if a non-qualifying individual occupies the home.
- It can also apply while the buyer takes steps, without undue delay, to use the home in the scheme before a placement is made.
- Those steps must be taken without undue delay.
- Registering for the scheme, with nothing more, does not meet HMRC’s stated test.
What this means in practice
The key issue is action rather than intention. After registering, a company should be able to show what it did, when it did it, and how each step moved the proposed scheme use forward.
Keep a clear record.
- Keep the scheme registration confirmation.
- Keep emails about matching or arranging a placement.
- Record offers to make the home available.
- Keep dates showing that the work moved forward promptly.
A claim can be lost where the conditions for keeping it are not met, especially if the records do not show prompt steps towards using the home for the scheme.
Evidence matters.
A vacant home may be easier to explain where there is good evidence of prompt efforts to use it for the scheme.
How to analyse it
Begin with the original claim. Then consider the later facts in date order.
What actually happened matters more than what the company hoped would happen.
- Check that paragraph 5 relief was claimed for the home.
- Identify the business purpose stated when it was bought.
- Check whether the home was occupied through Homes for Ukraine.
- Check whether any occupier was a non-qualifying individual.
- If no one moved in, list every step taken after registration.
- Ask whether those steps happened without undue delay.
Example
For example, North Street Lets Ltd claimed the relief after buying a home for its rental business.
It registers as a Homes for Ukraine sponsor, contacts the scheme team, offers the home for a placement and keeps the emails.
A family later stays there through the scheme. HMRC’s manual says this should not, on its own, withdraw the relief.
If the company only registered and then did nothing, HMRC says that is different.
Why this can be difficult in practice
The source does not give “Without undue delay” a fixed number of days. The timeline is therefore important.
Delays may happen, but the company needs evidence of what caused them, what it did in the meantime, and how it continued pursuing placement without undue delay.
Keep records.
- Do not assume registration proves active participation.
- Do not overlook who actually occupied the home.
- Do not treat HMRC’s manual as if it were the legislation.
- Check the current legal basis before relying on this treatment.
Key takeaways
- Homes for Ukraine hosting may preserve the relief under HMRC’s view.
- Registration alone is not enough.
- Good records of prompt action are vital.
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 5 — relief for qualifying property business purposes
- FA 2003 Schedule 4A para 5A — people who count as non-qualifying individuals
- FA 2003 Schedule 4A para 5G — three-year rules for keeping the relief
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 formal legal basis, start date and full scope of HMRC’s Homes for Ukraine treatment need checking against current primary legislation or any applicable regulations.
- Whether steps were taken without undue delay will depend on the evidence and the facts.
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 original SDLT return and details of the paragraph 5 relief claimed
- Proof that the home was bought solely for a qualifying business purpose
- Homes for Ukraine registration and sponsor records
- Records of contact, matching, offers of accommodation and dates
- Evidence of who occupied the home and under which immigration route
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 hosting and SDLT relief for company-owned homes [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 5 - relief for qualifying property business purposes https://www.legislation.gov.uk/ukpga/2003/14/schedule/4A/paragraph/5/2025-11-17 - FA 2003 Schedule 4A para 5A - people who count as non-qualifying individuals https://www.legislation.gov.uk/ukpga/2003/14/schedule/4A/paragraph/5A/2025-11-17 - FA 2003 Schedule 4A para 5G - three-year rules for keeping the relief https://www.legislation.gov.uk/ukpga/2003/14/schedule/4A/paragraph/5G/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/sdltm09656 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 formal legal basis, start date and full scope of HMRC's Homes for Ukraine treatment need checking against current primary legislation or any applicable regulations. - Whether steps were taken without undue delay will depend on the evidence and the facts. 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 hosting and SDLT relief for company-owned homes
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