Stamp Duty Explained: Why the Same House Is Taxed Four Different Ways

Stamp duty surprises buyers twice: first that it exists on top of the price, and then that it changes completely when you cross a border — sometimes a border inside the same country. A C$800,000 home in Ontario owes $12,475 of land transfer tax; the identical purchase inside Toronto owes exactly double. This guide explains what the tax is, who sets it, why the bands work the way they do, and what the same purchase costs across the four systems BeadCalc covers.

By the BeadCalc team · Last updated: October 23, 2026 · 7 min read

What stamp duty actually is

Stamp duty is a tax on a transaction, not on a thing. When ownership of a property changes hands, the state charges for recognising and recording that transfer — historically, the deed was only legally valid once it bore a physical stamp showing the duty had been paid. The paperwork is electronic now, but the logic is unchanged in the systems that kept the tax: no duty paid, no registered title. The tax goes by different names in different places — stamp duty in the UK, Australia and India, land transfer tax in most of Canada, transfer duty in parts of both — but it is the same species everywhere: a percentage of the price, charged to complete the purchase, on top of the price itself.

In almost every system the buyer pays it, and pays it at the sharp end of the purchase: at settlement or registration, in cash, alongside the deposit balance. It cannot usually be added to the mortgage (a lender lends against the property price, not the tax on it), which is why it belongs in the upfront-cash column of any affordability plan — as our affordability guide insists, the price is not the whole bill.

Why no two places charge the same

The single most important fact about stamp duty is who sets it: almost never the national government. Property records are a state, provincial or devolved competence in federal and devolved systems, so the tax is set — and kept — at that level:

  • The United Kingdom has three separate taxes: SDLT in England and Northern Ireland (set at Westminster), LBTT in Scotland and LTT in Wales (both devolved, both with their own bands).
  • In Canada the provinces set land transfer tax — and Toronto levies a second, municipal tax on top of Ontario's, while Alberta and Saskatchewan charge modest registration fees instead of a percentage tax at all.
  • In Australia, transfer duty is a state tax: six states and two territories, eight different schedules.
  • In India, stamp duty is a state subject under the constitution, and a separate registration charge rides alongside it — so two bills arrive wearing one name.

Because each level of government uses the tax as a policy lever as well as a revenue source, the schedules encode local politics: relief for first-time buyers where affordability is the pressure point, surcharges on additional properties where investors are the pressure point, concessions for women buyers in several Indian states, and thresholds that freeze or move with each budget. The result is that "the stamp duty on a home" is a meaningless phrase until you say exactly where the home is.

Bands: you never pay the top rate on the whole price

Nearly every system charges duty in marginal bands, exactly like income tax: each rate applies only to the slice of the price inside its band. The persistent myth that crossing a threshold taxes the entire price at the higher rate is wrong everywhere BeadCalc covers. Here is England's SDLT on a £350,000 main residence, band by band:

Slice of the priceRateDuty on the slice
£0 – £125,0000%£0
£125,001 – £250,0002%£2,500
£250,001 – £350,0005%£5,000
Total duty£7,500

The headline rate on that purchase sounds like 5%, but the effective rate is £7,500 ÷ £350,000 = 2.14%. Every comparison in this guide uses the effective rate, because that is what you actually pay. The current English bands continue at 10% from £925,001 and 12% above £1,500,000 — run any price through the UK stamp duty calculator to see its slices.

The same purchase, four tax systems

Now hold the purchase constant and move it around the map. Each row is computed with the current published bands in the linked calculator — same price within each country, wildly different bills:

WherePriceDuty (standard buyer)Effective rate
England (SDLT)£350,000£7,5002.14%
Scotland (LBTT)£350,000£8,3502.39%
Wales (LTT)£350,000£7,5002.14%
Ontario, CanadaC$800,000$12,4751.56%
Toronto, CanadaC$800,000$24,9503.12%
New South Wales, AustraliaA$800,000$30,1873.77%
Victoria, AustraliaA$800,000$43,0705.38%
Queensland, AustraliaA$800,000$21,8502.73%

Three stories hide in that table. First, devolution is not cosmetic: Scotland's LBTT starts taxing sooner and steps up faster than England's SDLT, while Wales reaches the same £7,500 by a completely different route (nothing to £225,000, then 6%). Second, Toronto is the world's cleanest illustration that this tax is local: the municipal tax mirrors Ontario's schedule, so a Toronto buyer pays the provincial $12,475 and then the same $12,475 again to the city. Third, Australia is the expensive outlier — and internally inconsistent: Victoria charges nearly double Queensland's duty on the same-priced home, a difference of $21,220 on one purchase. The calculators: Canada land transfer tax and Australia stamp duty.

India: two charges wearing one name

India deserves its own section because the bill splits in two: stamp duty proper, plus a registration charge for recording the deed — and both are state-set. On the same ₹75,00,000 (₹75 lakh) home, standard buyer, the totals from the India stamp duty calculator are:

StateStamp dutyRegistrationTotal
Maharashtra (Mumbai)₹4,50,000₹30,000 (capped)₹4,80,000
Delhi₹4,50,000₹75,100₹5,25,100
Karnataka₹4,20,000₹1,50,000₹5,70,000
Tamil Nadu₹5,25,000₹3,00,000₹8,25,000

Tamil Nadu tops the table because both halves are heavy: 7% duty plus a 4% registration charge. Karnataka's duty figure already includes its cess and surcharge on top of the band duty, and its registration charge rose to 2% of value in 2025 — the single biggest line after the duty itself. Maharashtra caps registration at ₹30,000 for most residential purchases, which is why Mumbai's total stays the lowest of the four despite a 6% headline duty (5% plus the Mumbai metro cess). The state-by-state guides linked from the calculator cover all eleven states in the comparison, including the municipal and rural variants inside Maharashtra.

Reliefs and surcharges: the same house, a different buyer

Everything above assumes a standard buyer of a main home. Change the buyer and the bill changes more than most price negotiations achieve:

  • First-time buyers: England's relief cuts the £350,000 bill from £7,500 to £2,500. Ontario refunds part of its tax to first-time buyers, and several Australian states waive or discount duty for first-home buyers below price caps.
  • Additional properties: buy a second home or a rental in England and the same £350,000 purchase is charged £25,000 — the standard bands with five extra points on each (Scotland's equivalent, the Additional Dwelling Supplement, adds 8 points). The surcharge exists to tilt the market toward owner-occupiers.
  • Women buyers in India: several states cut duty when a woman is the (or a joint) buyer. In Delhi the duty rate drops from 6% to 4%: on the ₹75 lakh home the total falls from ₹5,25,100 to ₹3,75,100 — ₹1,50,000 saved, the largest single "discount" available in any system in this guide, for the cost of putting the right name on the deed.

The lesson generalises: before negotiating the price by 1%, check whether your buyer category, the property's exact location (one street can cross a municipal line), or the structure of the purchase moves the tax by more.

When it is paid, and what happens if it is not

Timing is uniform in spirit everywhere: the duty is due at completion, and the transfer cannot be registered until it is paid. In India the deed is quite literally not registrable until duty and registration charges are settled, which is why the money moves before or at the registration appointment. In Australia duty is assessed on the contract and payable by settlement; in Canada the tax is collected on registration of the transfer; in the UK the return and payment follow completion within a short statutory window, and your conveyancer handles the filing. Practically: your solicitor, conveyancer or registration agent will ask for the duty money as part of the completion funds — never as an afterthought, because an unpaid duty means an unregistered home.

One last connection back to borrowing: because duty is paid in cash at completion, it shrinks the deposit you actually have. A buyer with $60,000 saved in New South Wales who spends $30,187 of it on duty is suddenly a sub-20%-down buyer with mortgage insurance to pay. Run the duty for your exact state and price first — UK, Canada, Australia, India — then feed what is left into the affordability calculator.

Run the numbers yourself

SDLT, LBTT and LTT band by band — standard, first-time buyer and additional-property rates.

UK Stamp Duty Calculator

This guide is educational. Its figures are worked examples computed with the site's own calculators from the rules and tables they cite; they are not financial or tax advice for your situation. Confirm the final figure with your lender, tax authority or a qualified professional before making decisions.

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