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Publication - Independent report

Land and Buildings Transaction Tax: review

Published
25 March 2026
From
Cabinet Secretary for Finance and Local Government
Directorate
Tax Directorate
Topic
Money and tax
ISBN
9781807751241

An independent analysis of certain aspects of Land and Buildings Transaction Tax (LBTT) policy.

View supporting documents Supporting documents

Appendix 2: Materiality analysis graphs and figures

Non-residential and mixed-use treatment

Table 18. Total revenue declared broken down by residential and non-residential property transactions
Year Total residential LBTT declared (£m) Total non-residential LBTT declared (conveyances) (£m) Percentage residential Percentage non-residential
2015/16 202 189.6 52% 48%
2016/17 290.2 154.9 65% 35%
2017/18 350.8 178.1 66% 34%
2018/19 353.5 168.8 68% 32%
2019/20 406.5 173.1 70% 30%
2020/21 366.4 125.3 75% 25%
2021/22 560.7 227 71% 29%
2022/23 620.6 190.8 76% 24%
2023/24 581 161.5 78% 22%
2024/25 683.5 202.7 77% 23%

Source: Revenue Scotland (2025c)

Figure 27. Residential vs non-residential LBTT declared (£m)
Line chart showing residential vs non-residential LBTT declared (£m) from 2015/16 to 2024/25. Total residential LBTT grows from around £200m in 2015/16 to around £700m in 2024/25, with a dip around 2020/21. Total non-residential LBTT remains relatively flat, fluctuating between around £150m and £250m throughout the period.

Source: Revenue Scotland (2025c)

Table 19. Total LBTT returns broken down by residential and non-residential property transactions
Year Total residential conveyance returns Total non-residential conveyance returns Percentage residential Percentage non-residential
2015/16 103,680 6,220 94% 6%
2016/17 100,500 6,810 94% 6%
2017/18 103,930 6,880 94% 6%
2018/19 103,750 7,160 94% 6%
2019/20 105,110 6,440 94% 6%
2020/21 96,850 5,930 94% 6%
2021/22 110,120 7,080 94% 6%
2022/23 102,580 7,050 94% 6%
2023/24 94,050 6,520 94% 6%
2024/25 102,100 7,470 93% 7%

Source: Revenue Scotland (2025c)

Table 20. Relief claims broken down by residential and non-residential transactions
Year Total residential LBTT relief claims Total non-residential LBTT relief claims[24] Percentage residential Percentage non-residential
2015/16 900 700 56% 44%
2016/17 1,050 770 58% 42%
2017/18 1,190 840 59% 41%
2018/19 9,180 840 92% 8%
2019/20 14,740 790 95% 5%
2020/21 2,310 730 76% 24%
2021/22 16,950 760 96% 4%
2022/23 17,010 840 95% 5%
2023/24 17,360 870 95% 5%
2024/25 21,360 1,070 95% 5%

Source: Revenue Scotland (2025c)

Table 21. Forgone earnings broken down by residential and non-residential transactions
Year Total residential LBTT forgone earnings (£m) Total non-residential LBTT forgone earnings (£m) Residential percentage Non-residential percentage Residential forgone earnings as percentage of residential revenue Non-residential forgone earnings as percentage of non-residential revenue
2015/16 15.4 108.6 12% 88% 8% 57%
2016/17 12.0 94.1 11% 89% 4% 61%
2017/18 12.2 80.6 13% 87% 3% 45%
2018/19 15.9 110.8 13% 87% 4% 66%
2019/20 17.3 94.6 15% 85% 4% 55%
2020/21 16.2 88.2 16% 84% 4% 70%
2021/22 35.5 96.8 27% 73% 6% 43%
2022/23 24.5 91.0 21% 79% 4% 48%
2023/24 37.3 146.5 20% 80% 6% 91%
2024/25 60.3 128.3 32% 68% 9% 63%

Source: Revenue Scotland (2025c)

Figure 28. Residential vs non-residential forgone earnings
Line chart showing residential vs non-residential forgone earnings (£m) from 2015/16 to 2024/25. Total non-residential forgone earnings are substantially higher throughout, fluctuating between around £80m and £110m till 2022/23, and rising sharply to around £145m in 2023/24 before falling slightly to around £130m in 2024/25. Total residential forgone earnings remain low and relatively stable below £20m till 2020/21, before rising to around £60m by 2024/25.

Source: Revenue Scotland (2025c)

Reliefs and exemptions (MDR, 6+ dwellings ADS exemption and first-time buyer relief)

Table 22. Forgone revenue by relief
Year MDR forgone revenue (£m) MDR forgone revenue as percent of total forgone revenue 6+ exemption forgone revenue (£m) 6+ exemption forgone revenue as percent of total forgone revenue First-time buyer relief forgone revenue (£m) First-time buyer relief forgone revenue as percent of total forgone revenue
2015/16 9.6 8% - - - -
2016/17 11.3 11% 3.4 3% - -
2017/18 14.2 15% 6.6 7% - -
2018/19 10.9 9% 3.8 3% 3.8 3%
2019/20 8.7 8% 4.6 4% 6.6 6%
2020/21 9.2 9% 3.5 3% 0.9 1%
2021/22 10.6 8% 4.2 3% 8.3 6%
2022/23 11.9 10% 4.1 4% 8.4 7%
2023/24 20.9 11% 6.2 3% 8.2 4%
2024/25 13.6 7% 7.8 4% 9.9 5%

Source: Revenue Scotland (2025c)

Table 23. Forgone revenue as percentage of total LBTT revenue
Year MDR forgone revenue as percent of total LBTT revenue 6+ exemption forgone revenue as percent of total LBTT revenue First-time buyer relief forgone revenue as percent of total LBTT revenue
2015/16 2% - -
2016/17 2% 1% -
2017/18 3% 1% -
2018/19 2% 1% 1%
2019/20 1% 1% 1%
2020/21 2% 1% 0%
2021/22 1% 1% 1%
2022/23 1.4% 0.5% 1.0%
2023/24 2.7% 0.8% 1.1%
2024/25 1.5% 0.8% 1.1%

Source: Revenue Scotland (2025c)

Figure 29. Revenue forgone by relief (£m)
Line chart showing revenue forgone by relief type (£m) from 2015/16 to 2024/25, covering MDR, the 6+ relief, and first-time buyers. MDR is the largest category across the period with a range of £10-£21m, peaking in 2023/24 before falling to around £13m in 2024/25. First-time buyer relief forgone grows gradually from near zero to around £10m by 2024/25. The 6+ relief rises initially and then remains relatively stable with a slight growth till £8m.

Source: Revenue Scotland (2025c)

Table 24. ADS revenues and claims
Year Net ADS revenues (£m) Number of residential claims including ADS after repayment Percentage of LBTT revenue from ADS Percentage of total residential LBTT claims including ADS
2016/17 77.3 17,190 17% 17%
2017/18 92.6 19,480 17% 19%
2018/19 94.5 19,260 17% 19%
2019/20 122 19,130 20% 18%
2020/21 112.4 16,970 22% 18%
2021/22 147.5 21,410 18% 19%
2022/23 159 20,960 19% 20%
2023/24 163.1 17,250 21% 18%
2024/25 204.3 18,620 22% 18%

Source: Revenue Scotland (2025c)

Figure 30. ADS revenue vs total LBTT revenue (£m)
Grouped bar chart showing total LBTT revenue vs net ADS revenue (£m) from 2016/17 to 2024/25. Total LBTT revenue grows from around £470m in 2016/17 to around £925m in 2024/25, with a dip in 2020/21. Net ADS revenue grows broadly in line, from around £80m to around £200m over the same period, consistently representing a minority share of total LBTT revenue.

Source: Revenue Scotland (2025c)

Table 25. ADS forgone revenues
Year ADS revenue forgone (£m) Returns which include forgone ADS revenue ADS forgone revenue as percentage of total forgone revenue Percent of relief claims including ADS exemption
2015/16 - - - -
2016/17 3 210 3% 11%
2017/18 6.2 250 7% 12%
2018/19 4.3 310 3% 3%
2019/20 5.7 410 5% 3%
2020/21 3.6 240 3% 8%
2021/22 5.3 310 4% 2%
2022/23 13.2 870 11% 5%
2023/24 27.1 1,780 15% 10%
2024/25 43.3 2,670 23% 12%

Source: Revenue Scotland (2025c)

Figure 31. ADS revenue forgone vs total revenue forgone (£m)
Line chart showing ADS revenue forgone vs total LBTT revenue forgone (£m) from 2015/16 to 2024/25. Total LBTT revenue forgone fluctuates between around £95m and £190m, rising sharply from 2022/23 onwards to reach around £190m in 2024/25. ADS revenue forgone remains very low and close to zero until around 2021/22, before rising to around £45m by 2024/25.

Source: Revenue Scotland (2025c)

Table 26. First-time buyer relief claims
Year Number of first-time buyer relief claims Percentage of total relief claims Percentage of total LBTT returns
2019/20 13,230 85% 11%
2020/21 1,940 64% 2%
2021/22 16,220 92% 13%
2022/23 16,070 90% 14%
2023/24 15,650 86% 14%
2024/25 18,810 84% 15%

Source: Revenue Scotland (2025f)

Contact

Email: devolvedtaxes@gov.scot

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