donaldross.co.uk Donald Ross Estate Agents Limited, Registered in Scotland No.SC29018 Directors: Jacqueline Miller & Fraser Stewart 1. 2. UK PROPERTY TAX DIFFERENCES: ENGLAND VS SCOTLAND England • When you buy a property in England you normally pay Stamp Duty Land Tax (SDLT). • If it’s a second home (i.e., you still own another property anywhere in the world when you complete the purchase), you usually pay an additional 3% on top of standard SDLT rates. • You may be eligible for a refund of the extra SDLT if you sell your previous main residence within 36 months of completing the purchase. Scotland (Ayrshire) • Scotland doesn’t use SDLT. Instead, you pay Land and Buildings Transaction Tax (LBTT). • If the property you’re buying in Scotland would be an additional home (because you still own your English property), you’ll usually pay the Additional Dwelling Supplement (ADS) — currently 8% on top of LBTT — unless you qualify for relief. • Councils in Scotland can also charge higher Council Tax on second homes (often up to double the standard rate), including in South Ayrshire, East Ayrshire, and North Ayrshire where that power has been enacted. BUYING BEFORE YOU SELL: WHAT HAPPENS? A. Stamp Duty / LBTT / ADS • Buying before you sell your English home typically means lenders/land tax authorities will treat your new property purchase as a second home until your old one is sold. • That generally triggers: • Extra SDLT in England if buying there first, or • ADS in Scotland if buying in Ayrshire first. Example: If you agree to buy a house in Ayrshire while your English property is still owned, that Ayrshire purchase could attract the ADS (8% of the full purchase price), even if you intend to sell your English home soon after. 26/01/2026 England to K E Y P R O P E R T Y B U Y E R I N F O R M AT I O N M O V I N G F R O M Ayrshire donaldross.co.uk Donald Ross Estate Agents Limited, Registered in Scotland No.SC29018 Directors: Jacqueline Miller & Fraser Stewart B. Claiming Relief • In England, you can usually claim back the extra SDLT if you sell your existing home within 36 months of buying the new one. • In Scotland, ADS relief may be available if you’re buying a new main residence and selling your existing sole/main residence, provided the sale happens within a certain timeframe (often 18 months, though exact rules vary). You’ll need to apply for this via Revenue Scotland. • It’s crucial to plan this carefully with your solicitor/conveyancer so the ADS refund is claimed successfully. 26/01/2026 3. PRACTICAL TIPS AND THINGS TO BE AWARE OF A. Timing Matters • If you sell your English home before completing on the Scottish property, you’re much more likely to avoid the ADS or extra SDLT altogether. • If you buy first, you often pay the extra tax up front and then seek relief or refund later. This can affect cash flow. B. Council Tax on Second Homes • In Scotland, council tax on second homes can be significantly higher (often doubled) in many local authorities, including South Ayrshire, East Ayrshire and North Ayrshire, unless a specific exemption applies. • Make sure to check the specific council tax policy where you plan to buy. C. Capital Gains Tax (when Selling) • Selling your main home in England is usually exempt from Capital Gains Tax due to private residence relief. However, CGT can apply if the property isn’t your main home or has been used as a rental/second home. • Always confirm with a tax advisor or solicitor whether your situation qualifies for relief. D. Professional Advice is Important • Solicitor/Conveyancer: Property tax rules differ between England and Scotland. A conveyancer familiar with both jurisdictions can help structure the timing and applications for refunds/reliefs. • Financial Adviser/Tax Expert: For detailed tax planning — especially involving ADS, SDLT refunds, and potential CGT. England to K E Y P R O P E R T Y B U Y E R I N F O R M AT I O N M O V I N G F R O M Ayrshire donaldross.co.uk Donald Ross Estate Agents Limited, Registered in Scotland No.SC29018 Directors: Jacqueline Miller & Fraser Stewart 26/01/2026 4. SUMMARY ISSUE ENGLAND (IF BUYING BEFORE SELLING) SCOTLAND (AYRSHIRE) Property Tax when buying Extra SDLT (3%) ADS (8%) + LBTT Can you get refund? Yes, within 36 months Possible relief if timed with sale Council Tax concerns Depends on local authority Possible second-home premium (up to 2×) Capital Gains on sale Usually exempt if main home Not applicable unless property was second home England to K E Y P R O P E R T Y B U Y E R I N F O R M AT I O N M O V I N G F R O M Ayrshire