Policy paper published on changes to First-time Buyers' Relief rules

HMRC has published a policy paper and draft legislation changing the rules for claiming Stamp Duty Land Tax First-time Buyers' Relief, covering leases held through nominees or bare trustees and the definition of a first-time buyer.

HM Revenue & Customs published a policy paper on 6 March 2024 setting out changes to the rules for claiming Stamp Duty Land Tax First-time Buyers' Relief1. The paper states that the measure covers two areas: claims where a new lease is granted through a nominee or bare trustee, and the definition of "first-time buyer" used for the relief1.

"This measure makes changes to the rules for claiming First-time Buyers' Relief where a new lease is granted through a nominee or bare trustee."
HMRC, Stamp Duty Land Tax: First-time Buyers' Relief1

The paper also states that the measure "makes changes to the definition of 'first-time buyer' for the purposes of the relief"1. The publication includes a one-page draft legislation PDF on bare trusts, alongside an accessible HTML version of the draft legislation1.

The policy paper does not set out the new wording of the first-time buyer definition, the rates of relief, or the date any change takes effect. Those details are not in the published paper, and no commencement date has been reported1. The paper was published on 6 March 2024 and carries no further updates1.

Why it matters for households

First-time Buyers' Relief reduces the Stamp Duty Land Tax bill for eligible people buying a first home, so the definition of who counts as a first-time buyer determines who can claim it. A change to that definition could alter which buyers qualify, and a change to the claim rules for leases granted through a nominee or bare trustee could affect how a claim is made where the property is held that way. The paper does not say who gains or loses eligibility, or from when, so the practical effect on individual buyers has not been reported1.

Anyone buying in England or Northern Ireland pays Stamp Duty Land Tax, and the relief sits within the wider set of Stamp Duty reliefs and exemptions. The existing first-time buyer relief rules and the current definition of a first-time buyer remain as published until any change takes effect. Buyers using co-ownership or holding property through a trust are among those potentially affected by the lease and nominee element, though the paper gives no detail on how relief above a set threshold or other thresholds would be treated.

What happens next

The paper was published with draft legislation on 6 March 20241. No date for the changes to take effect, and no consultation or parliamentary timetable, is given in the paper1.

Sources1 cited
  1. Stamp Duty Land Tax: First-time Buyers’ Relief - GOV.UK gov.uk