United Kingdom – Property Taxes

What taxes and fees apply when buying a property in the UK?

Acquiring property in the UK means taking on a range of costs that go well beyond the agreed purchase price. The most substantial of these is the transfer tax — called Stamp Duty Land Tax (SDLT) in England and Northern Ireland, Land and Buildings Transaction Tax (LBTT) in Scotland, and Land Transaction Tax (LTT) in Wales. Each of these nations operates independently set rates and thresholds, so your location of purchase has a meaningful bearing on the overall tax bill.

Stamp Duty Land Tax (England & Northern Ireland)
SDLT is levied on buyers when they acquire houses, flats, land, or buildings in England and Northern Ireland. Despite its historical name, it no longer involves physical stamping of documents — it functions as a self-assessed transfer tax submitted directly to HMRC. The rates were revised on 1 April 2025, when the residential nil-rate threshold reverted to £125,000 following the expiry of a temporary relief that had been in place. This represents a return to the pre-pandemic position.

SDLT rate bands for standard residential buyers (as of April 2025):

SDLT operates as a progressive banded system — much like income tax — meaning each rate applies only to the portion of the purchase price that falls within a given band rather than to the total price. Buyers have 14 days from completion to submit an SDLT return and settle any tax due. Failure to meet this deadline can result in penalties and interest charges from HMRC.

First-time buyer relief: With effect from 1 April 2025, first-time buyers are charged 0% SDLT on the portion of a property’s value up to £300,000, and 5% on any value between £300,001 and £500,000. Where the purchase price exceeds £500,000, the first-time buyer relief is not available and the full standard rate table applies.

Additional dwelling surcharge: Since 31 October 2024, buyers who will own more than one residential property as a result of their purchase must pay an additional 5% on top of standard SDLT rates. This affects second homes, buy-to-let acquisitions, and holiday properties. This kind of investor or multi-property surcharge is a measure also seen in Australia and Canada, where transfer taxes are structured to discourage non-owner-occupier purchases.

Beyond SDLT, buyers in England and Wales will typically also face:

• Legal/conveyancing fees: Fees charged by your solicitor or licensed conveyancer generally fall between £1,000 and £3,000 or more, depending on the value and complexity of the transaction.
• Land Registry registration fee: HM Land Registry charges a fee to record the change of ownership; this follows a sliding scale linked to property value and commonly amounts to a few hundred pounds for most residential sales. Consult the HM Land Registry fee schedule for up-to-date figures.
• Survey/valuation fee: Depending on whether you commission a basic valuation, a homebuyer report, or a full structural survey, expect to pay between £300 and £1,500.
• Mortgage arrangement fees: Where a mortgage is involved, lender arrangement charges can vary from nothing to over £2,000.
• Search fees: Local authority, drainage, and environmental searches collectively tend to cost in the region of £250–£500.

Worked example (as of April 2025, England): Consider a standard residential buyer — not a first-time buyer and not acquiring an additional property — purchasing a home for £350,000.

On a £600,000 property, the SDLT alone would come to £20,000 (calculated as 0% on £125k, 2% on £125k, and 5% on £350k). For an accurate figure specific to your purchase, use the HMRC SDLT calculator.

What taxes and fees apply when selling a property in the UK?

The UK does not impose a dedicated transfer tax on sellers — in contrast to certain other countries where both parties to a transaction pay their own separate levy. For most sellers, the principal costs consist of professional fees, and — where a taxable gain has been made — Capital Gains Tax on the profit realised (discussed in the following section).

Estate agent fees represent the largest single expense for most sellers. Agents in the UK typically charge a percentage of the final sale price, usually somewhere between 1% and 3% plus VAT at 20%, depending on whether you opt for a traditional high-street agency, an online agent, or a hybrid model. On a £350,000 sale at a 1.5% commission rate, the agent’s charge would be £5,250 before VAT, rising to £6,300 inclusive of VAT.

Conveyancing fees are also incurred by sellers, generally in the range of £800–£2,000, covering the preparation of the contract pack, management of title deeds, and coordination of funds transfer on the day of completion.

Energy Performance Certificate (EPC) — a valid EPC is a legal requirement before a property can be listed for sale. If yours has expired or you do not have one, a fresh assessment typically costs between £60 and £120 and remains valid for 10 years.

Mortgage exit or redemption fees may be applied by your lender if you pay off your mortgage ahead of schedule, particularly where you remain within a fixed-rate deal. Early repayment charges can range from a modest sum to several thousand pounds, depending on the lender and the terms of your mortgage.

Unlike France, where the involvement of a notaire is a legal requirement for property transactions, the UK process is managed by solicitors or licensed conveyancers, each party appointing their own representative. Always obtain a clear breakdown of expected costs from your conveyancer before proceeding.

Is capital gains tax payable on property sales in the UK?

Capital Gains Tax (CGT) is levied on the profit arising when someone disposes of an asset whose value has risen since acquisition. The charge falls on the gain itself — not on the full sale proceeds — and specific rules govern how property gains are calculated and reported.

Main home exemption (Private Residence Relief): Where the property being sold is your principal residence, Private Residence Relief (PRR) removes any CGT liability. This is among the most generous tax reliefs available to UK property owners and means that the overwhelming majority of owner-occupiers face no CGT bill when they move. The concept is broadly comparable to the primary residence exemption in Australia or the home sale exclusion in the United States.

CGT rates on residential property (as of 2025/26):
Gains on residential property are charged at 18% for basic-rate taxpayers and 24% for higher-rate taxpayers. These rates were unchanged by the 2024 and 2025 Budget announcements; although other CGT rates were raised to align with them, the residential property rates themselves held steady.

Annual exempt amount: Each individual can realise a certain level of gains in any tax year before CGT becomes due. For 2025/26, this annual exemption stands at £3,000. It is worth noting that this figure has contracted sharply from £12,300 just a few years ago, drawing many more property sellers into the CGT net as a result.

Calculating the gain: Certain costs can be deducted when working out your net gain for CGT purposes. These include the original stamp duty paid, solicitor and estate agent fees on both purchase and sale, and the cost of capital improvements — such as adding an extension — but not routine maintenance or decoration.

Reporting deadline: When CGT is due on a UK property disposal, it must be reported and paid within 60 days of the completion date. This is a firm deadline, and missing it will attract automatic penalties from HMRC.

Non-residents: Disposing of UK property can give rise to a CGT liability even for individuals who are not UK tax-resident. The same 60-day reporting window applies. Where a property was acquired before April 2015, it is permissible to rebase its value to 6 April 2015, limiting the chargeable gain to growth from that date onward — a potentially significant saving for long-term overseas owners.

Practical example: Suppose a second home was bought in 2018 for £200,000 and is sold during 2025/26 for £280,000. The gross gain is £80,000. Deductible costs include the original SDLT (say £1,500), legal fees on purchase (£1,200), a kitchen extension costing £10,000, and agent fees on sale (£4,200) — a total of £16,900. The resulting net gain is £63,100. After deducting the annual exempt amount of £3,000, the taxable gain comes to £60,100. For a higher-rate taxpayer, CGT at 24% produces a bill of £14,424. For your specific circumstances, refer to HMRC’s CGT guidance or speak with a qualified tax adviser.

Are there annual property taxes in the UK?

Council tax is the main recurring property-related tax across the UK — though technically it falls on whoever occupies a property rather than being a pure ownership charge. It is an annual levy collected by local authorities in England, Scotland, and Wales to fund services such as rubbish collection, street maintenance, and social care. Introduced in April 1993 to replace the Community Charge (popularly known as the poll tax), the amount payable depends on both the property’s valuation band and the rate set by the relevant local council. Unlike the taxe foncière in France or the annual property tax in the United States — which are primarily owner-based obligations — UK council tax generally falls on the occupier, though owners of vacant properties can still face charges.

How bands are calculated: In England, properties are divided into eight bands (A through H) according to their estimated capital value as at 1 April 1991. Band A covers properties worth up to £40,000 at that date, with Band H covering those above £320,000. Each band attracts a payment expressed as a fixed fraction of the Band D rate, running from 6/9 for Band A to 18/9 (double) for Band H. Every local authority sets its own Band D rate annually. Crucially, the valuations are frozen at their 1991 levels — a property worth £300,000 in today’s market may still sit in Band C or D based on what it was worth over three decades ago.

Typical annual amounts (as of 2025/26): The average Band D property in England attracts a bill of £2,171, though a single band increase to Band E pushes this to £2,654 — a difference of £483. There is wide geographical variation, with London averaging around £1,700 while several northern and Midlands councils exceed £2,500 for Band D properties. Check your band via the Valuation Office Agency (England and Wales).

Discounts and exemptions: Single-person households qualify for a 25% discount, a concession that applies to around 30% of all properties. Full-time students living alone are fully exempt. Individuals with disabilities may qualify for a reduction of one band.

Second homes and empty properties: A substantial increase in council tax premiums is affecting owners of second homes and long-term empty properties. From 1 April 2026, councils may levy a 100% premium on homes that have been unoccupied for as little as one year. Research published in December 2025 found that 211 councils are already charging double the standard rate on second homes.

High Value Council Tax Surcharge (coming April 2028): The Autumn Budget 2025 announced the widely expected High Value Council Tax Surcharge (sometimes called a “Mansion Tax”), which will apply in England from April 2028 to homes valued above £2 million, be charged across four bands, and include five-yearly revaluations. At most, this would amount to 0.15% of a property’s value annually, with the maximum charge of £7,500 applying to homes valued at £5m or above. For the latest details, visit GOV.UK’s council tax pages.

Northern Ireland operates a different regime: domestic rates rather than council tax. These are calculated on the basis of the capital value of your property. The NI Direct website provides current rate information.

How is rental income from property taxed in the UK?

In the UK, rental income does not attract a dedicated landlord tax — it is treated as property income and charged to Income Tax in the usual way. Landlords are required to declare this income through Self Assessment, and the applicable tax rate reflects their total taxable income for the year, using the standard income tax bands: 20% at the basic rate, 40% at the higher rate, and 45% at the additional rate for 2025/26.

Allowable deductions for landlords include:

• Letting agent fees and management charges
• Buildings and contents insurance
• Maintenance and repairs (not improvements)
• Accountancy fees
• Ground rent and service charges (leasehold properties)
• Mortgage interest — but with an important restriction (see below)

Mortgage interest restriction: Since April 2020, individual landlords have been unable to deduct mortgage interest directly from rental income as an expense. In its place, a tax credit equivalent to 20% of finance costs is available. For higher-rate taxpayers, this change substantially increases the effective tax rate on rental profits and is a critical factor for leveraged buy-to-let investors to consider. Companies holding property are not subject to this restriction.

Property Income Allowance: Every individual receives a £1,000 annual property income allowance. Those with total rental receipts below this threshold have nothing to report or pay. Where income exceeds £1,000, landlords may choose between deducting their actual allowable expenses or claiming the flat £1,000 allowance — whichever produces the more favourable outcome.

Non-resident landlords: Where a landlord lives outside the UK, tenants and letting agents are generally obliged to deduct 20% tax at source from rental payments under the Non-Resident Landlords (NRL) scheme, unless HMRC grants approval for payment to be made gross. Landlords wishing to receive income without deduction can apply to HMRC and instead account for tax through Self Assessment. Further information is available at HMRC’s non-resident landlord guidance.

Short-term lets (Airbnb and similar platforms): The Furnished Holiday Lettings (FHL) tax regime was abolished from April 2025. Properties previously classified as FHLs now fall within the individual’s standard UK or overseas property business, meaning the favourable treatment that once allowed full mortgage interest deductions and access to certain CGT reliefs no longer applies. Short-term rental income is now taxed in the same manner as conventional residential letting income. The Rent-a-Room scheme continues to offer a £7,500 annual tax-free allowance to those letting a furnished room within their own home.

Reporting: Landlords must enrol for Self Assessment and file an annual tax return. The deadline for online submissions is 31 January each year, covering the preceding tax year. All income and expenditure records should be retained for a minimum of five years.

Does inheritance tax apply to property in the UK?

Inheritance Tax (IHT) is charged on the total estate — including property — of a deceased person. It is administered by HMRC and falls primarily on the estate’s executor or personal representative rather than on beneficiaries directly. The UK’s IHT framework is broadly analogous to estate taxes in countries such as Ireland and the United States, though rate structures and available reliefs differ considerably.

Rates and thresholds: IHT is levied at a flat rate of 40% on the net value of an estate above the nil-rate band. The nil-rate band is set at £325,000 and has been frozen at this figure until at least 5 April 2030. Any portion of an estate below this threshold is free of IHT.

Residence nil-rate band (RNRB): An additional nil-rate band called the “residence nil-rate band” is also frozen at £175,000, as is the residence nil-rate band taper starting at £2 million. These are frozen until 5 April 2030. The RNRB applies when a main residence is passed to direct descendants (children, grandchildren), potentially bringing the total tax-free allowance up to £500,000 per individual, or £1,000,000 for a married couple or civil partners combining their allowances.

Spouse/civil partner exemption: Assets transferred between spouses or civil partners — whether during life or on death — are fully exempt from IHT regardless of the sums involved. Any unused portion of a deceased spouse’s nil-rate bands can be transferred to the surviving partner.

Non-residents and foreign nationals: UK-situated real estate forms part of a chargeable estate for IHT purposes regardless of the deceased’s nationality or domicile. For those who are UK-domiciled, IHT applies to their worldwide estate. The UK has entered into double taxation conventions with a number of countries which may prevent the same assets from being taxed twice. Details of these agreements can be found at HMRC’s international affairs pages.

Pensions and IHT from April 2027: The government will bring unused pension funds and death benefits payable from a pension into a person’s estate for IHT purposes from 6 April 2027. This is a significant change for those using pensions as part of estate planning and may indirectly affect property-related estate strategies.

Agricultural and business property relief: From 6 April 2026, agricultural and business property will continue to benefit from 100% IHT relief up to a combined limit of £1 million. Property in excess of the limit will benefit from a 50% relief. This is particularly relevant to those inheriting farms or rural estates.

Does gift tax apply to property transfers in the UK?

There is no standalone gift tax in the UK. That said, property transferred as a gift during a person’s lifetime can still carry IHT implications through the concepts of “Potentially Exempt Transfers” (PETs) and “Chargeable Lifetime Transfers” (CLTs). This sets the UK apart from countries such as France, which operates a distinct gift tax regime (droits de donation) with its own separate thresholds and graduated rates.

Potentially Exempt Transfers (PETs): Gifting a property to another individual (rather than a trust) triggers no immediate IHT charge. However, should the donor die within seven years of making the gift, the full value of the transferred property is drawn back into the estate for IHT calculation purposes. If the donor survives the seven-year period, the gift falls entirely outside the estate and no IHT arises. Where death occurs between three and seven years after the gift, tapering relief gradually reduces the IHT exposure.

Capital Gains Tax on gifts: Even where no IHT liability arises at the point of transfer, gifting a property is treated as a disposal at market value for CGT purposes. If the property has grown in value since acquisition and does not qualify for Private Residence Relief, a CGT charge may crystallise at the moment of gifting — at 18% or 24% for residential property in 2025/26. This is a frequently overlooked consequence of property gifting.

Spousal transfers: Transferring assets to a spouse or civil partner — whether by gift or sale — can be done without triggering a chargeable CGT gain. Such transfers are also exempt from IHT.

Annual gift allowance: Each person benefits from a £3,000 annual IHT gift exemption, meaning gifts up to this value each year are outside the scope of IHT. Any unused allowance from the previous tax year may be carried forward for one year. Individual small gifts of up to £250 per recipient are also exempt. Given the scale of property values, these allowances offer only modest protection in the context of real estate gifting, making professional tax advice essential before proceeding.

If you are contemplating transferring property to a family member, it is strongly advisable to seek guidance from a qualified UK tax adviser and solicitor in advance. The interplay between CGT, IHT, and SDLT — which may apply where the recipient assumes a mortgage — can be complex and costly if not properly managed.

Are there any tax advantages or incentives for buying property in the UK?

Despite the generally high transactional tax burden, the UK provides several reliefs and incentives that can produce meaningful savings for qualifying buyers and investors.

First-time buyer SDLT relief: From 1 April 2025, first-time buyers are charged 0% SDLT on the portion of a property’s value up to £300,000, and 5% on the portion between £300,001 and £500,000. A first-time buyer purchasing at £280,000, for instance, would pay no stamp duty whatsoever — a saving of £3,100 relative to a standard buyer at the same price.

Private Residence Relief (PRR): The full gain arising on the sale of your main home is free of CGT, provided you occupied it throughout the period of ownership. Even where you let out the property for a time, or rented a portion of it to lodgers, partial relief may still be available. This represents the most significant property tax relief available to owner-occupiers in the UK.

Individual Savings Accounts (ISAs) and the Lifetime ISA: The government’s Lifetime ISA (LISA) enables those aged 18–39 to contribute up to £4,000 per year towards the purchase of a first home (on properties priced up to £450,000), with the state adding a 25% bonus to contributions. All growth within the account is tax-free, providing both a financial incentive and a tax-efficient savings wrapper for prospective first-time buyers.

Shared Ownership: Government-backed shared ownership schemes allow buyers to acquire a proportion of a property — typically 25% to 75% — while paying rent on the remaining share. This reduces the purchase price subject to SDLT. Some schemes permit buyers to pay SDLT only on the initial share acquired, deferring any further tax liability until they purchase additional shares through the staircasing process.

Zero-rate VAT on new builds: Newly constructed residential properties are zero-rated for VAT, meaning the purchase price carries no VAT charge. Certain qualifying renovation and conversion projects may also attract a reduced 5% VAT rate. This treatment differs from commercial property, which is governed by separate VAT rules.

Investor incentives: While the Furnished Holiday Lettings regime has been abolished (from April 2025), commercial property held within a Self-Invested Personal Pension (SIPP) can still benefit from tax advantages for eligible investors — though residential property cannot generally be held directly within a SIPP.

Given the frequency with which relief conditions are updated, always confirm current eligibility with the HMRC SDLT guidance pages or a qualified professional adviser before relying on any particular relief.

Do different rules apply to foreign buyers or non-residents?

The UK imposes no blanket restriction on foreign nationals purchasing residential or commercial property. Unlike New Zealand, which has introduced constraints on overseas residential acquisitions, there is no requirement to hold citizenship or permanent residency status to buy property in the UK. However, several additional tax charges are directed specifically at non-residents.

Non-resident SDLT surcharge: Since 1 April 2021, higher SDLT rates have applied to purchasers of residential property in England and Northern Ireland who are not UK-resident. These rates are 2 percentage points above those charged to UK residents. The surcharge extends to both freehold and leasehold acquisitions. Buyers who have not been present in the UK for at least 183 days (six months) during the 12-month period before their purchase are treated as non-UK resident for SDLT purposes.

Combined surcharges for non-resident investors: A non-resident acquiring an additional residential property — such as a buy-to-let — in England faces the standard SDLT rates plus the 5% additional-dwelling surcharge plus the 2% non-resident surcharge, representing a combined additional burden of 7 percentage points above the standard rate. On a £400,000 purchase, this could generate approximately £28,000 in additional SDLT compared with what a UK-resident first-time buyer would pay.

Non-resident CGT: Non-UK residents are liable to UK CGT on gains arising from the disposal of UK land and UK property-rich entities, subject to the terms of any applicable double tax treaty. The same 60-day reporting requirement applies as for UK residents. Where the property was originally purchased before April 2015, the gain may be rebased to 6 April 2015, potentially reducing the taxable amount significantly for those who have owned property in the UK over a long period.

Non-resident landlords: As described in the rental income section, tenants or letting agents dealing with a non-resident landlord are generally required to withhold 20% basic-rate tax from rental payments unless HMRC has authorised gross payment.

Annual Tax on Enveloped Dwellings (ATED): From 31 October 2024, SDLT is charged at 17% on interests in residential dwellings costing more than £500,000 purchased by certain non-natural persons (i.e. companies and collective investment schemes). Residential properties held within a corporate structure may also be subject to the Annual Tax on Enveloped Dwellings (ATED), which is a separate recurring annual charge. Refer to HMRC’s ATED guidance for current rates and thresholds.

Mortgage and AML requirements: Non-resident and foreign-national buyers may encounter more extensive anti-money-laundering (AML) due diligence from solicitors and lenders alike. Mortgage availability tends to be more restricted for non-residents, with fewer lenders active in this market and higher deposit requirements typically imposed. Obtaining independent legal advice from a UK-qualified solicitor is strongly recommended before proceeding with a purchase.

How do I apply for and pay SDLT — a step-by-step guide?

1. Instruct a solicitor or licensed conveyancer. They will handle the SDLT return on your behalf as part of the conveyancing process.
2. Calculate your SDLT liability. Use the HMRC SDLT calculator to estimate the amount owed, taking into account your residency status, whether the purchase constitutes an additional property, and any applicable reliefs such as first-time buyer relief.
3. Complete the SDLT return (form SDLT1). Your solicitor will ordinarily prepare and submit this electronically to HMRC on your behalf.
4. Pay the SDLT due. The SDLT return must be filed and any tax paid within 14 days of completion. Payment is made by bank transfer or CHAPS; HMRC does not accept credit card payments for SDLT.
5. Receive your SDLT certificate. Upon receipt of your return, HMRC issues an SDLT5 certificate. Your solicitor requires this document to register the title with HM Land Registry.
6. Registration at HM Land Registry. Your solicitor submits the title registration application to HM Land Registry together with the SDLT certificate and the applicable Land Registry fee. Completion of registration formally establishes your legal ownership of the property.

Frequently asked questions about property taxes in the UK

Do I have to pay SDLT if I am gifted a property rather than buying it?

SDLT is only triggered on a gift where the recipient takes on a mortgage or other debt secured against the property. If the property is conveyed without any associated debt, no SDLT liability arises. However, if the property has risen in value since the donor acquired it and it is not their primary residence, CGT may be payable by the donor at the point of transfer. Always take legal advice before proceeding with a property gift.

Can I reclaim the additional 5% SDLT surcharge if I sell my previous home?

The 5% surcharge will not apply if the property you are buying is replacing your main residence and your previous main home was sold within 36 months of completing the new purchase. If you paid the surcharge because you had not yet disposed of your former home at the time of completion, you can seek a refund from HMRC — provided the previous main residence is sold within 36 months. Consult HMRC’s guidance for the current refund procedure.

Is council tax payable by the owner or the tenant in a rental property?

Council tax liability generally rests with whoever is occupying the property, which in a tenancy arrangement means the tenant while they are in residence. When a property stands empty between lettings, the obligation reverts to the owner. Some councils extend a limited discount for short-term vacancies, but many now apply a premium to properties left unoccupied for extended periods. The allocation of responsibility should always be clarified clearly within the tenancy agreement.

How does CGT work for non-residents who inherit UK property?

Inheriting property does not in itself attract CGT — a beneficiary is treated as having acquired the property at its market value on the date of death (the probate value). CGT only becomes relevant if the beneficiary subsequently sells the property and it has appreciated in value since the inheritance date. The 60-day CGT reporting rule applies to non-residents disposing of UK residential property, and any potentially applicable double-tax treaty should be examined. A UK tax adviser with experience in cross-border estates should be consulted in these circumstances.

Do I need to register for Self Assessment just because I own a rental property?

Yes. Where rental income exceeds your annual Property Income Allowance of £1,000, or where it exceeds £2,500 after deducting allowable expenses, registration for HMRC Self Assessment and the annual submission of a tax return are obligatory. Even where you consider that no tax is ultimately owed, a reporting obligation may still exist. You can register at HMRC’s Self Assessment registration page.

Are there any property taxes specific to Scotland and Wales that differ from England?

Property purchases in Scotland are subject to Land and Buildings Transaction Tax (LBTT), while those in Wales attract Land Transaction Tax (LTT) — both replacing SDLT in their respective nations and each operating under distinct rate tables and thresholds. Scotland additionally levies an Additional Dwelling Supplement on second home and buy-to-let acquisitions. Council tax in Scotland follows the same banding structure as England but with rates determined independently by Scottish local authorities. Always check the rules applicable to the specific nation in which you are buying.

What happens to my UK property for IHT purposes if I am not domiciled in the UK?

UK-situated real estate is always within the scope of UK Inheritance Tax, irrespective of the nationality or domicile of the deceased. This means that even a foreign national who is not domiciled in the UK will have their UK property counted as part of a chargeable estate on death. Overseas assets may fall outside the UK IHT net depending on the individual’s domicile status. Where the UK has a bilateral estate tax treaty with the deceased’s home country, double taxation may be mitigated. Given the significant changes to domicile and residence rules introduced from April 2025, specialist advice from a cross-border estate planning professional is essential.

Can I avoid SDLT by buying through a company structure?

From 31 October 2024, SDLT is charged at 17% on interests in residential dwellings costing more than £500,000 purchased by certain non-natural persons such as companies. This higher rate is specifically intended to discourage avoidance through corporate enveloping. Acquiring property via a company can in some situations be advantageous for portfolio landlords, but the elevated entry-level SDLT charge, the ongoing ATED liability, and the corporation tax treatment must all be carefully modelled before any decision is made. Qualified advice from a UK accountant or tax adviser is indispensable in this area.