When Chancellor John Healey delivered his first Budget on 28th October 2026, the headline for the property market was the one most people expected. Stamp Duty Land Tax rates, thresholds and surcharges were left exactly as they were. The Prime Minister had ruled out reform back in July, so there was no surprise for home movers, no new relief for downsizers and no change to the surcharge on additional dwellings.
But no change to SDLT rates is not the same as no change to SDLT. Tucked away in the Budget documents and HMRC’s overview of tax legislation and rates are several technical measures, two of which took effect within a day of the Chancellor sitting down. For conveyancing firms, the detail matters far more than the headline. Here is what changed, what stayed the same and what it means for the matters on your desk right now.
Group relief clawback tightened with immediate effect
The most significant change for commercial and corporate work concerns group relief. Under the existing rules, where property moves between companies in the same group, group relief can remove the SDLT charge. If the purchasing company then leaves the group within three years, the relief is clawed back and the SDLT becomes payable.
The government has amended the rules so that the winding up of the vendor company no longer prevents that clawback. In other words, liquidating the seller will not protect the relief if the buyer later leaves the group within the three year window. The change applies to transactions with an effective date on or after 29th October 2026. It will be legislated in Finance Bill 2026/27, but it already has effect through a resolution under the Provisional Collection of Taxes Act 1968.
Firms advising on intra group transfers, reorganisations or the later sale of a property holding company should revisit any structure that relied on the vendor being wound up. Share sale documentation for a company that acquired property under group relief in the last three years will also need careful attention, including warranties and indemnities covering a potential clawback charge.
No more SDLT on rent under assured tenancies
This is the change most likely to reach residential practitioners. The Renters’ Rights Act made assured tenancies periodic, which created an unexpected problem. Under the existing SDLT rules for leases that continue beyond their original term, a tenant who stayed in a property long enough could build up a liability for SDLT on rent, along with an obligation to file a return. Most tenants would have had no idea.
The government first announced a fix in a Written Ministerial Statement on 22nd April 2026 and the Budget confirmed it. Legislation in Finance Bill 2026/27 will remove SDLT on the rent element of assured tenancies and remove the requirement to file an SDLT return solely because rent is payable under an assured tenancy. The change has effect from 1st May 2026.
There are transitional provisions for tenancies entered into before 1st May 2026. These preserve the SDLT treatment of the original tenancy, including any SDLT already due, while ensuring that no further SDLT on rent arises as the tenancy continues. Commercial leases are outside the scope of this change, so the normal lease calculations still apply there.
A new relief for Local Government Pension Scheme pooling
The Budget introduced a new SDLT relief for the pooling of land and property into Local Government Pension Scheme asset pool companies, following an announcement at Budget 2025. The relief applies to acquisitions made by qualifying collective investment vehicles established or managed by LGPS asset pool companies. It covers transactions with an effective date on or after 28th October 2026 and before 1st April 2032 and, like the group relief change, already has effect through a Provisional Collection of Taxes Act resolution ahead of Finance Bill 2026/27.
This is specialist territory and most high street firms will never see a qualifying transaction. Even so, it is a reminder that SDLT reliefs are narrow and conditional. A relief only helps when every condition is met and the claim is made correctly on the return.
Sovereign investors and a temporary relief ahead of 2029
The government has also published a consultation on a new Sovereign Tax Status regime for foreign states, heads of state and state entities investing in the UK. Certain income and gains will be brought into direct taxation, with the reforms taking effect from 1st January 2029. Transitional provisions will include a time limited SDLT relief for restructuring certain existing property holdings before that date. Legislation will follow in a future Finance Bill, so this one is worth watching rather than acting on for now.
The views expressed in this feature are those of the author and not those of Today’s Conveyancer.
