Revenue eBrief No. 037/23 – Stamp Duty Tax and Duty Manual – "Section 31E: Stamp duty on certain acquisitions of residential property (10% rate of duty)" – Updated


Revenue eBrief No. 037/23

24 February 2023

Stamp Duty Tax and Duty Manual – “Section 31E: Stamp duty on certain acquisitions of residential property (10% rate of duty)” – Updated

Tax and Duty Manual (TDM) – Stamp duty on certain acquisitions of residential property (10% rate of duty) – contains guidance on the application of section 31E of the Stamp Duties Consolidation Act 1999 (SDCA). This section provides for stamp duty to be charged on certain acquisitions of residential property at a higher rate of 10%.

The TDM has been updated to reflect changes made by Finance Act 2022 to section 31E, including:

  • Clarifying that the acquisition of a partial interest in a residential property is within the scope of section 31E, and
  • Providing that home reversion firms are excluded from the scope of section 31E. 

The TDM has also been updated in sections 5 and 6.3 to further clarify that indirect acquisitions are within scope of section 31E.

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