UK Property Ownership Structures

Buying in your own name is the default, and at £2 million it is usually the right answer for a home you will live in. SDLT runs through the ordinary bands, giving £153,750 where you are replacing your only or main residence. A non-resident adds 2 percentage points on the whole price; an additional dwelling adds 5.

There is no annual wrapper charge: no ATED, no company accounts, no corporate filings. From April 2028 the High Value Council Tax Surcharge of £2,500 to £7,500 a year will apply to high-value homes based on 2026 valuations, but that lands on the property whoever owns it, so it does not distinguish between structures.

The trade-offs are on exit and succession. UK residential property is within the scope of UK inheritance tax regardless of where the owner lives, and personal ownership offers no privacy from the public register of title.

A company buying a single dwelling for more than £500,000 pays a flat 17% SDLT on the whole price, with no bands and no nil-rate slice. A non-UK resident company adds the 2 percentage point surcharge, making 19%. At £2,000,000 that is £340,000 or £380,000.

The recurring cost is ATED: £32,200 a year for a property in the £2m–£5m band in 2026-27. Reliefs remove the charge where the property is genuinely let to unconnected tenants or held as trading stock, but the relief has to be claimed on a return every year, and the charge revives if a connected person occupies the property.

An SDLT relief exists for acquisitions by a qualifying property rental business, which restores the ordinary rates plus the additional-dwelling surcharge. Like the ATED relief, it is conditional and subject to clawback if the qualifying use ceases. Corporate ownership makes most sense where there is a real letting business, meaningful debt, or a succession plan built around share transfers.

Trusts are a succession and control tool that happens to hold property, not a stamp duty strategy. The SDLT treatment depends on the trust: with a bare trust, HMRC generally looks through to the beneficiary and taxes the purchase as if the beneficiary bought it. With a discretionary or other substantive trust, the trustees are the buyers, and where a trustee is a company or other non-natural person the 17% flat rate can apply.

The recurring position is equally fact-dependent. A trust holding UK residential property directly through individual trustees is outside ATED; a trust holding through a company is not. Relevant-property trusts face their own inheritance tax cycle of ten-year and exit charges, and UK trusts and many non-UK trusts with UK assets must register on the Trust Registration Service.

In practice, a trust is worth its complexity where the objective is controlling who benefits and when — protecting minors, managing a blended family, or holding a home across generations — rather than reducing the cost of the purchase.

Most prime London flats are leasehold, and lease length affects value more than structure does. As at August 2026 marriage value has not been abolished: the relevant provisions of the Leasehold and Freehold Reform Act have not yet been commenced, so on a lease with fewer than 80 years unexpired the premium to extend still includes a share of the marriage value payable to the freeholder.

That is a live number on a £2 million purchase. A short lease can cost six figures to extend, and it is not a cost any ownership structure removes. Establish the unexpired term and the extension position before you decide who is buying.

Start with the use. A home you or your family will occupy points strongly to personal ownership, because the corporate route costs more on entry and attracts ATED with no letting relief available. A genuinely let portfolio is where the company begins to compete, particularly if it is financed.

Then look at your horizon. The corporate premium at £2 million is £46,250 to £126,250 of extra SDLT depending on the comparison, plus up to £32,200 a year. That has to be recovered over the holding period from something real — interest relief, rollover of profits, or a succession benefit — not from an assumption.

Finally, price the exit. De-enveloping later can trigger tax at both company and shareholder level, and moving property into trust is a chargeable event in its own right. The cheapest structure is the one you choose once, before exchange.

Single residential property in England or Northern Ireland at £2,000,000. Figures current as at August 2026.

From April 2028 the High Value Council Tax Surcharge of £2,500–£7,500 a year applies to high-value homes based on 2026 valuations, whoever owns them. Figures current as at August 2026.

Worked Example: The Corporate Premium at £2m

A non-UK resident buying a £2,000,000 London home as an additional dwelling, comparing personal ownership with a non-resident company over five years.

£86,250 of additional SDLT plus £161,000 of ATED. The comparison assumes no ATED relief, which is the position for a home occupied by the owner or family. Where the property is genuinely let to unconnected tenants and reliefs are properly claimed, the recurring gap can fall to nil — but the entry premium remains.

Every figure on this page is taken from the following official guidance, checked on 15 August 2026.

• GOV.UK: Stamp Duty Land Tax — residential property rates
• GOV.UK: Rates of Stamp Duty Land Tax for non-UK residents
• GOV.UK: Annual Tax on Enveloped Dwellings — the basics