Schedule 4ZA temporarily modified by the Stamp Duty Land Tax (Temporary Relief) Act 2023

The Stamp Duty Land Tax (Temporary Relief) Act 2023 modified Schedule 4ZA of the Finance Act 2003 from 8 February 2023, changing the higher rates of stamp duty land tax for additional dwellings.

Schedule 4ZA of the Finance Act 2003, which sets the higher rates of stamp duty land tax for additional dwellings and dwellings bought by companies, was modified temporarily from 8 February 2023 by section 1 of the Stamp Duty Land Tax (Temporary Relief) Act 20231. The same Act also modified Schedule 6ZA, which provides relief for first-time buyers, on the same date3.

Schedule 4ZA was inserted by section 128(3) of the Finance Act 20161. It had previously been modified temporarily by the Stamp Duty Land Tax (Temporary Relief) Act 20201. The 2023 modification was itself later amended by the Finance Act 2025, with effect in accordance with section 50(3) of that Act1.

The higher rates in Schedule 4ZA apply to the part of the relevant consideration falling in each band1:

Part of relevant considerationPercentage
So much as does not exceed £125,0005%
So much as exceeds £125,000 but does not exceed £250,0007%
So much as exceeds £250,000 but does not exceed £925,00010%
So much as exceeds £925,000 but does not exceed £1,500,00015%
The remainder (if any)17%

A transaction falls within the higher rates rules for a single dwelling where the purchaser is an individual, the main subject matter is a major interest in a single dwelling, and Conditions A to D are met2. Condition A is that the chargeable consideration is £40,000 or more1. Condition C requires the purchaser to hold a major interest in another dwelling with a market value of £40,000 or more at the end of the effective date2. Condition D is that the purchased dwelling is not a replacement for the purchaser's only or main residence2. A replacement can be established where the purchaser disposed of a major interest in another dwelling in a transaction whose effective date fell within the three years ending with the effective date of the purchase, and that sold dwelling was the purchaser's only or main residence at some time in that period1. A purchase can also be a replacement where the disposal happens in the three years beginning with the day after the effective date of the purchase, or such longer period as HMRC may allow where exceptional circumstances prevented disposal within that period1. An application for a longer period must be made within 12 months beginning with the effective date of the transaction disposing of the major interest in the sold dwelling1.

For first-time buyers, relief may be claimed where the main subject matter is a major interest in a single dwelling, the relevant consideration other than rent is not more than £500,000, and each purchaser is a first-time buyer who intends to occupy the dwelling as their only or main residence3. Relief cannot be claimed if the transaction is a higher rates transaction for the purposes of paragraph 1 of Schedule 4ZA3. Where relief applies, the rates are 0% on so much as does not exceed £300,000 and 5% on any remainder so far as not exceeding £500,0003.

"Sch. 4ZA modified (temp.) (8.2.2023) by Stamp Duty Land Tax (Temporary Relief) Act 2023 (c. 2), s. 1"
Finance Act 2003, source1

Why it matters for households

The modification took effect on 8 February 2023 and applies to transactions with that effective date1. It affects buyers of additional dwellings, including those who already own a home with a market value of £40,000 or more, and companies buying dwellings, who pay the higher rates set out in the table1. It also affects first-time buyers claiming relief under Schedule 6ZA, because relief is unavailable where the transaction is a higher rates transaction3. The rates and thresholds above are the figures recorded in the legislation as modified, and the 2023 modification was later amended by the Finance Act 20251. The sources do not state the end date of the temporary modification, so this has not been reported.

What happens next

The legislation records that the modification was amended by the Finance Act 2025, with effect in accordance with section 50(3) of that Act1. No further dated steps are set out in the sources.

For more on Stamp Duty Land Tax in England and Northern Ireland, Stamp Duty reliefs and exemptions and Stamp Duty first-time buyer relief, see the site's home-buying pages.

Sources4 cited
  1. Finance Act 2003 legislation.gov.uk
  2. Finance Act 2003 (c. 14) legislation.gov.uk
  3. Finance Act 2003 legislation.gov.uk
  4. Finance Act 2003 (c. 14) legislation.gov.uk