Stamp Duty Land Tax Rates and Reliefs for Corporate Bodies

SDLT for Companies and Other Non-Natural Persons Buying Residential Property

When a company or certain other non-natural persons buy a residential property for more than £500,000, SDLT may be charged at a flat 17% rate unless a specific relief applies. Even if that 17% charge is reduced or removed, separate SDLT surcharges and possibly the Annual Tax on Enveloped Dwellings may still need to be considered.

• The 17% SDLT rate can apply to residential purchases over £500,000 by a company, a partnership with a corporate partner, or a collective investment scheme.
• The 17% rule does not apply if a company buys the property as trustee of a settlement.
• Relief may be available for certain cases, including property rental businesses, developers or traders, public access trades, lending businesses, employee occupation, farmhouses, and qualifying housing co-operatives.
• Relief is not automatic: the legal conditions must be met, and the actual use of the property matters.
• Separate charges may still apply, including the 5% surcharge for company purchases and, in England and Northern Ireland, the 2% non-UK resident surcharge where relevant.
• Homes for Ukraine rules can preserve an existing relief from the 17% charge, but they do not create a new relief where none already applies.

Scroll down for the full analysis.

SDLT on residential property bought by companies and other non-natural persons

This page explains the special SDLT rules that can apply when a residential property is bought by a company or certain other non-natural persons. The key point is that some purchases of dwellings costing more than £500,000 are charged at a flat 17% rate, unless a specific relief applies. Separate surcharges may also apply, so the total SDLT position can be significantly higher than many buyers expect.

What this rule is about

SDLT has special rules for residential property acquired by certain entities rather than by individuals. HMRC refers to these entities as corporate bodies or non-natural persons. The rule is aimed at purchases of higher-value dwellings that are being acquired through a company or similar structure.

According to the HMRC guidance, the 17% rate can apply where a residential property costing more than £500,000 is bought by:

• a company
• a partnership with one or more corporate partners
• a collective investment scheme

The guidance also makes clear that this 17% rate does not apply where a company buys the property as trustee of a settlement.

This is a distinct charging rule. It sits alongside other SDLT surcharges and alongside the separate Annual Tax on Enveloped Dwellings regime, which may also matter where a dwelling is held through a company or similar structure.

What the official source says

HMRC states that SDLT is charged at 17% on residential properties costing more than £500,000 bought by certain corporate bodies or non-natural persons.

HMRC also states that relief from that 17% charge may be available if the property falls within one of the listed categories, including where the property is:

• used in a property rental business
• bought by a property developer or trader
• used in a trade that makes the property available to the public
• bought by a financial institution in the course of lending
• occupied by employees of the purchaser
• a farmhouse
• bought by a qualifying housing co-operative

HMRC emphasises that the conditions for the relevant relief must be met. The guidance does not say that relief is automatic just because the buyer describes itself as, for example, a developer or landlord.

The page also explains a specific protection linked to the Homes for Ukraine Sponsorship Scheme. If the buyer already qualifies for relief from the 17% rate, that relief will continue where the property is occupied by individuals admitted under that scheme, including where they later move to the Ukraine Permission Extension Scheme. Relief is also not withdrawn where the buyer is taking steps, without delay, to use the property as part of those schemes.

Finally, HMRC says there are additional surcharges:

• a 5% surcharge on residential properties bought by companies
• a further 2% surcharge for residential properties in England and Northern Ireland bought by non-UK residents on or after 1 April 2021

HMRC states that the 2% non-UK resident surcharge applies on top of all other residential SDLT rates, including the 5% higher rate surcharge.

What this means in practice

The first practical question is whether the buyer is the kind of entity covered by the rule. If the purchaser is a company, a collective investment scheme, or a partnership with a corporate partner, the special regime may be in point.

The second question is whether the property is residential and whether the price is more than £500,000. If both are true, the 17% flat rate becomes a live issue.

The third question is whether one of the statutory reliefs is available. In many commercial situations, that is the critical issue. For example, a company buying dwellings for a genuine rental business or as part of a development trade may fall within a relief, but only if the detailed conditions are satisfied.

If no relief applies, the 17% rate can produce a very high SDLT charge. If relief does apply, that does not necessarily mean the transaction falls outside SDLT surcharges altogether. HMRC’s page separately points to the 5% surcharge for company purchases of residential property, and potentially the 2% non-UK resident surcharge as well.

So in practice, the analysis is not simply:

• Is the buyer a company?

It is more like:

• Is this a residential acquisition by a non-natural person?
• Does the 17% rule potentially apply?
• Is there a relief from that charge?
• Do any separate surcharges still apply?
• Could the property also fall within the Annual Tax on Enveloped Dwellings rules after completion?

How to analyse it

A sensible way to approach the issue is as follows.

• Identify the buyer. Is it a company, a partnership with a corporate member, or a collective investment scheme?
• Check whether the buyer is instead acting as trustee of a settlement. HMRC says the 17% rate does not apply in that case.
• Confirm that the property is residential for SDLT purposes.
• Check the consideration. The HMRC page only brings the 17% rate into play where the residential property costs more than £500,000.
• Consider each possible relief carefully. Do not rely on labels. The actual use of the property and the statutory conditions matter.
• If relief appears available, consider whether it is preserved or protected in the Homes for Ukraine context.
• Then consider the separate surcharges, especially the 5% surcharge for company purchases and, where relevant, the 2% non-UK resident surcharge.
• Finally, consider whether the structure may also expose the owner to Annual Tax on Enveloped Dwellings.

For conveyancers and advisers, the main risk is treating the 17% rule as if it were the whole SDLT answer. It is not. Relief from the 17% charge and liability to surcharges are related but separate questions.

Example

A company buys a residential property in England for more than £500,000. On the face of it, the purchase falls within the category that can attract the 17% SDLT rate for non-natural persons.

If the company is buying the property to use in a qualifying property rental business, relief from the 17% charge may be available, provided the conditions for that relief are met.

That does not end the analysis. The company must still consider the separate 5% surcharge for residential property bought by companies. If the buyer is also non-UK resident and the transaction is within the relevant date range, the 2% non-UK resident surcharge may also need to be added.

If the same property is then occupied under the Homes for Ukraine Sponsorship Scheme, HMRC says that relief already obtained from the 17% charge is not withdrawn merely because of that occupation, and the same protection extends where individuals later move to the Ukraine Permission Extension Scheme.

Why this can be difficult in practice

The HMRC page is short, but the underlying rules are not simple.

First, relief depends on meeting specific conditions. Whether a property is genuinely used in a property rental business, acquired by a qualifying developer or trader, or made available to the public in the right way can be fact-sensitive.

Second, readers often confuse relief from the 17% charge with exemption from all higher residential SDLT charges. HMRC’s page shows that this is not the same thing. A transaction may escape the 17% flat rate but still face the 5% surcharge, and possibly the 2% non-UK resident surcharge as well.

Third, the page refers to Annual Tax on Enveloped Dwellings. That is a different regime from SDLT on acquisition, but in practice the same corporate ownership structure may trigger both sets of issues.

Fourth, the Homes for Ukraine material is limited in scope. It protects relief that already exists. It does not create a new general relief where none previously applied.

Key takeaways

• A 17% SDLT rate can apply to residential property costing more than £500,000 bought by companies and certain other non-natural persons.
• Relief may be available, but only if the detailed conditions for the relevant relief are met.
• Even where the 17% charge is relieved, separate SDLT surcharges and possibly Annual Tax on Enveloped Dwellings may still need to be considered.

This page was last updated on 24 March 2026

Useful article? You may find it helpful to read the original guidance here: Stamp Duty Land Tax Rates and Reliefs for Corporate Bodies

View all HMRC SDLT Guidance Pages Here