Higher rate of Stamp Duty for multiple acquisitions of residential property

A higher rate of Stamp Duty on the multiple acquisitions of residential property was introduced in May 2021. This was under Section 31E of the Stamp Duties Consolidation Act 1999 (SDCA).

The higher rate of duty is currently 15% for instruments executed on or after 2 October 2024. It was previously 10% between May 2021 and October 2024.

This rate of duty applies where a person acquires 10 or more residential units (excluding apartments) in any 12-month period.

Exclusions for apartments

The higher rate does not apply where a residential unit in an apartment block is acquired. Under section 31E SDCA an apartment block is a building that comprises three or more apartments with grouped or common access.

How the charge is applied

This higher rate applies when 10 or more residential units are acquired within a rolling 12-month period by a company or an individual. Acquisitions by connected persons (such as companies under the same control) are aggregated to determine if the 10-unit threshold has been met.

The 12-month period is a rolling window. For every new property acquired, Revenue looks back at the previous 12 months to see if the 10-house threshold has been met.

The higher rate can apply to both:

  • direct acquisitions
  • and
  • indirect acquisitions.

A residential property may be acquired indirectly where a person acquires:

  • shares, stocks or marketable securities in a company
  • units in Irish Real Estate Funds (IREFs)
  • or
  • interests in partnerships

that derives value directly or indirectly from residential property.

For further information, please refer to the Tax and Duty Manual on Section 31E. 

Note

Section 83DB SDCA provides for a partial repayment of Stamp Duty paid at the higher rate of 15% in certain circumstances. Further information on Section 83DB can be found at Section 83DB Repayment of Stamp Duty in respect of certain residential units.