Stamp Duty vs Frais de Notaire: What You Actually Pay When Buying Property in the UK and France (2026)

Disclaimer: This article is for general information only and does not constitute legal, tax, or financial advice. UK Stamp Duty Land Tax and French frais de notaire are technical, both regimes have moved repeatedly in the last two years, and the consequences of misreading the bands are real. Consult a qualified solicitor in the UK or a notaire in France. The English Investor accepts no liability for decisions taken on the basis of this article.

A London-based investor is choosing between a £500,000 flat in Camden and a €500,000 apartment in the 11th arrondissement. Both as second homes. Same money, broadly comparable square metreage, similar yield profile. Before she opens a spreadsheet she wants to know what the transaction tax bill actually looks like in each market — what the UK calls Stamp Duty Land Tax, what the French call frais de notaire, and which is, in fact, the cheaper acquisition.

The short answer is that the two regimes are not just numerically different but structurally different. UK SDLT is a single tax that scales sharply with property value and adds surcharges for additional dwellings and non-resident purchasers. French frais de notaire is a bundle of taxes, levies and fees — most of which never reaches the notary — that runs at a fairly flat percentage regardless of value but knows almost nothing about a buyer’s residence status or how many homes they already own. For a primary-residence buyer at £500,000, the UK is dramatically cheaper. For a second-home or non-resident buyer, France is the cheaper jurisdiction. For new-build property, France is dramatically cheaper still. The mechanics are worth walking through, because the way these two regimes are commonly explained in headline form gets the comparison wrong as often as it gets it right.

UK Stamp Duty Land Tax in 2026 — the bands you actually pay

Stamp Duty Land Tax applies to residential property purchases in England and Northern Ireland (Scotland levies its own Land and Buildings Transaction Tax, Wales its own Land Transaction Tax, with similar but distinct band structures). For purchases from 1 April 2025 onwards — the date the COVID-era temporary nil-rate uplift expired — the standard residential bands for a buyer acquiring a single property are 0% up to £125,000, 2% on the portion from £125,001 to £250,000, 5% on the portion from £250,001 to £925,000, 10% on the portion from £925,001 to £1.5 million, and 12% on the remaining amount above £1.5 million. The bands apply marginally: a £500,000 purchase is taxed at 0% on the first £125,000, 2% on the next £125,000 and 5% on the final £250,000, for an SDLT bill of £15,000 — about 3.0% of the price.

First-time buyers — defined as anyone who has never previously owned a residential interest anywhere in the world, buying their first home and intending to live in it — get a separate, more generous band structure. From 1 April 2025 they pay 0% up to £300,000 and 5% on the portion from £300,001 to £500,000, with the relief cutting out completely above £500,000. A first-time buyer at the £500,000 ceiling pays £10,000, exactly 2.0%; a first-time buyer at £500,001 pays the full standard bands without relief. The cliff is sharp by design.

If the property being bought is not the only residential property the buyer owns at the end of completion day — typically a second home, a buy-to-let, or a holiday home — every band of the standard schedule is increased by five percentage points. The higher rates were raised from a three-point surcharge to a five-point surcharge by Chancellor Rachel Reeves’s October 2024 Budget, taking effect on 31 October 2024 and unchanged since. At £500,000, the higher rates work out to 5% on the first £125,000, 7% on the next £125,000 and 10% on the final £250,000, for a £40,000 bill — 8.0% of the price, or £25,000 more than a primary-residence buyer at the same price would pay.

And if the buyer is not UK-resident — defined for SDLT purposes as not being present in the UK for at least 183 days during the twelve months before the purchase — a further 2% non-resident surcharge is layered on top of whatever the resident rate would have been. The non-resident surcharge has been in place since 1 April 2021 and applies in addition to the additional-dwelling surcharge. A non-resident buying a £500,000 second home in May 2026 pays £40,000 of higher-rate SDLT plus £10,000 of non-resident surcharge — £50,000 total, exactly 10.0% of the price.

Two further structural points are worth flagging. SDLT is collected by HMRC through an SDLT return that must be filed within fourteen days of completion, with payment due on the same timeline; missed deadlines carry their own penalty regime. And companies buying residential property worth more than £500,000 fall into a 17% flat-rate corporate SDLT charge (unless they qualify for the relevant trading or letting-business reliefs), which sits alongside the Annual Tax on Enveloped Dwellings — a wholly separate annual levy on residential property worth over £500,000 held through a non-natural person. For an ordinary individual buyer, none of this is in scope; for anyone considering a corporate holding structure on the UK side, the £500,000 threshold is the trigger to think about carefully.

French frais de notaire — what’s actually in them

The first thing worth saying about “frais de notaire” is that the name is misleading: the notary, in the French sense of an officier public ministériel handling the conveyance, collects only a small fraction of the total. The rest is tax. The composition of the French acquisition cost on an existing-build (ancien) residential property in 2026 is broadly four pieces — taxes paid to the state, the département and the commune (the largest piece by far); the contribution de sécurité immobilière paid to the state cadastre service; the notary’s own regulated emoluments; and a smaller envelope of débours covering miscellaneous formality costs and external disbursements.

The dominant piece is the bundle commonly called Droits de Mutation à Titre Onéreux (DMTO) or Taxe de Publicité Foncière (TPF), which between them capture the bulk of the transfer-tax burden. The components are a departmental rate, a communal rate, and a state collection levy assessed on the departmental rate. From 1 April 2025 onwards — and the mechanics of the DMTO hike are walked through in our dedicated article — the départements were given the option to raise the departmental rate from the historical 4.50% to 5.00% for acts signed between 1 April 2025 and 31 March 2028. The communal rate is 1.20% and unchanged. The state collection levy is 2.37% of the departmental tax. The all-in DMTO/TPF rate for an ancien purchase in a département that has voted to apply the hike is therefore 5.00% + 1.20% + (2.37% × 5.00%) = 6.3185%, rounding to 6.32% in practice. In départements that have stuck with the 4.50% rate, the all-in is 5.807%. The great majority of mainland départements have moved to the higher rate.

The Loi de Finances 2025 carved out a specific exemption: a primo-accédant — someone who has not been the owner of their main residence in the two years preceding the act, and who is buying the new property as their main residence — is not subject to the additional 0.5 percentage points. They continue to pay the 4.50% departmental rate, for an all-in DMTO/TPF of 5.807%. The carve-out is meaningful but narrowly drawn: it does not apply to second homes, to investment purchases, or to anyone who has owned their main residence in the last two years.

The contribution de sécurité immobilière (CSI), a levy charged by the state cadastre service for the registration of the act, is 0.10% of the price. It is small in absolute terms but invariant.

The notary’s own emoluments are regulated by the Code de commerce — most recently by the arrêté of 25 February 2026, effective 1 March 2026 and in force until 28 February 2028 — and follow a four-band degressive schedule under article A444-91: 3.945% on the portion of the price from 0 to €6,500; 1.627% on the portion from €6,500 to €17,000; 1.085% on the portion from €17,000 to €60,000; and 0.814% on the portion above €60,000. The notary’s emoluments are subject to 20% VAT. For a €500,000 property, the marginal computation gives total emoluments of €4,475 before VAT and €5,370 after VAT — slightly over 1.0% of the price.

The débours envelope covers external disbursements paid by the notary on the buyer’s behalf — cadastral extracts, mortgage register searches, certain stamp duties on the deed itself, postage, and similar — and typically runs €800 to €1,500 depending on the complexity of the file and the property’s history. It is not a “fee” in the sense of remuneration; it is a pass-through of real out-of-pocket costs.

Adding the four pieces on a €500,000 ancien purchase in a département at the 5.00% rate gives a total of roughly €31,592 of DMTO/TPF + €500 of CSI + €5,370 of emoluments TTC + €1,200 of débours = about €38,660, or 7.7% of the price. The conventional rule of thumb that “frais de notaire on the ancien run 7 to 8%” is approximately accurate; the precise figure depends on the département and the buyer’s status.

The composition mismatch — and why the comparison is so often miscalled

The reason headline comparisons of “UK Stamp Duty vs French notary fees” so often confuse the picture is that the two terms describe structurally different things. UK SDLT is a single tax, paid to HMRC, that adjusts in response to who the buyer is (UK resident or not, first-time or not, additional-dwelling or not) and what they are buying (residential or commercial, single property or six or more in one transaction). It does not adjust to where in the country the property sits, and the residence-status weighting is heavy.

French frais de notaire is a bundle of four mostly fixed-rate items that adjust to where the property sits (the départemental DMTO rate is set locally within the 4.50% to 5.00% statutory range), to whether the property is ancien or new-build (the carve-out for VEFA is decisive — more in a moment), and, narrowly, to whether the buyer qualifies as a primo-accédant on a main-residence purchase. It does not adjust to a buyer’s UK or other foreign residency, to the number of properties the buyer already owns elsewhere, or to whether the property is being acquired for investment versus owner-occupation.

The headline number people quote — “frais de notaire are 7 to 8%” — is the all-in transaction cost on an ancien, which makes the right comparison against the total SDLT including any surcharges, not against the SDLT base rate alone. Conversely, the headline number for UK SDLT in everyday conversation tends to be the standard-residential rate (which is 3.0% effective at £500,000), which understates what most non-resident or additional-property buyers will actually pay. Comparing 3% to 7% is not the comparison; comparing 10% to 7.7% on the same buyer profile is.

Side-by-side at £500,000 and €500,000 — the worked numbers

One refinement worth flagging on the comparison: the table assumes the French DMTO is paid in a département applying the 5.00% rate. A handful of départements have either kept the historical 4.50% rate or applied it only to a portion of transactions — Paris and the Île-de-France region applied the full 5.00% from June 2025, but local variations exist. For practical purposes, anyone buying anywhere outside an obvious metropolitan area should ask their notary to confirm the applicable departmental rate before signing the compromis. The all-in cost of buying a Parisian pied-à-terre is worked through in detail in our dedicated article, including the FX and ongoing-holding components that this article deliberately leaves to one side.

The non-resident angle — where the two regimes diverge most sharply

UK SDLT applies a 2% surcharge to any buyer not resident in the UK for at least 183 days during the twelve months before completion. The surcharge is structural — it sits on top of any other rate that would otherwise apply, including the additional-dwelling +5 percentage points — and was introduced on 1 April 2021 specifically to dampen the cost-of-housing impact of overseas investment. The surcharge applies regardless of nationality; a British citizen who has been working abroad and meets the day-count test triggers it just as readily as a Hong Kong-based investor with no UK link.

France has no symmetric acquisition-stage non-resident surcharge. A British, American or other foreign buyer pays exactly the same DMTO, CSI, emoluments and débours as a French-domiciled buyer of identical property. The cross-border tax adjustment for non-residents is not in the acquisition itself but in the ongoing holding (the taxe foncière and, for letting income, the social-charge stack), and in the disposal (the non-resident prélèvement under article 244 bis A of the CGI). For an acquisition decision in isolation, the residency of the buyer is — almost uniquely among major Western jurisdictions — neutral in French frais de notaire.

This single structural difference accounts for most of the case where a non-resident concludes that buying in France is cheaper than buying in the UK. A non-resident buyer at £500,000 in England pays £50,000 of SDLT, including the +2% non-resident layer and the +5 pp additional-dwelling layer (on the safe assumption that any non-resident is also a multiple-property owner globally). The same buyer at €500,000 in France pays around €38,660. The €11,000-or-so absolute difference — or roughly 2.3 percentage points effective — is the price of being non-resident in a UK acquisition that simply does not exist on the French side.

Second homes and additional dwellings

UK SDLT treats the second home with a +5 percentage point surcharge on every band, raised from +3 pp in the October 2024 Budget and in force from 31 October 2024. The surcharge applies on the basis of a global headcount — if the buyer (or anyone they are married to, in a civil partnership with, or buying with) owns any residential property anywhere in the world worth £40,000 or more at the end of completion day, the additional dwelling rates kick in. The implication for an internationally-domiciled buyer is that even a small co-owned holiday home anywhere globally is enough to trigger the +5 pp escalation on a UK acquisition.

France does not have a parallel additional-dwelling surcharge on acquisition. The buyer of a second home in France pays the same frais de notaire as the buyer of a first home, subject only to the primo-accédant carve-out from the +0.5 pp DMTO hike (which applies only to first-time main-residence buyers and not to second-home purchases regardless). The differential cost of holding a French second home arrives later, in the form of the taxe d’habitation surtax that many tourist-area communes apply to non-primary-residence dwellings, and in capital-gains exposure on disposal — both important but neither sits in the acquisition transaction tax line.

First-time buyer relief — UK substantial, France narrow

UK first-time-buyer relief, post the 1 April 2025 narrowing of the thresholds, gives a 0% rate up to £300,000 and a 5% rate on the portion from £300,001 to £500,000, with no relief at all above £500,000. The relief is meaningful: a first-time buyer at the £500,000 ceiling pays £10,000 of SDLT versus the £15,000 a repeat buyer at the same price would pay — a £5,000 saving, or one percentage point of the purchase price. The cliff above £500,000 is sharp; a first-time buyer at £500,001 pays the full standard bands without the relief.

The French primo-accédant carve-out introduced by the Loi de Finances 2025 is narrower in scope and smaller in monetary value. It removes only the +0.5 percentage point departmental DMTO hike — the savings on a €500,000 purchase amount to €2,500, about 0.5 percentage points of the purchase price, against a baseline acquisition cost of around 7.2% to 7.7%. The carve-out is structured as an exemption from a rate increase rather than as a positive incentive, and it operates only between 1 April 2025 and 31 March 2028 — the same window over which the DMTO hike itself applies. Once the temporary departmental flexibility ends in 2028, both the hike and the primo-accédant exemption disappear together.

New builds — France’s big structural advantage

The single largest structural divergence between the two regimes is on new-build property. A French logement neuf — broadly any residential property whose first sale takes place within five years of completion, including off-plan VEFA purchases — does not attract the DMTO/TPF rate at all. The applicable transfer-tax line is a reduced taxe de publicité foncière of approximately 0.715%, in lieu of the 5.81% to 6.32% that would otherwise apply on the ancien. The contribution de sécurité immobilière at 0.10% remains payable, the notary’s emoluments and débours are unchanged, and the all-in frais de notaire on a €500,000 new build runs around €10,000 to €11,000 — about 2.0 to 2.2% of the price, against 7.2% to 7.7% on an equivalent ancien.

The economic logic is that new builds are subject to TVA at 20% on the purchase price itself (paid to the developer, not the notary), and the reduced TPF avoids the double-taxation that the full DMTO would otherwise generate. The reduced rate is automatic on a qualifying VEFA or new build and applies regardless of buyer status. For a foreign buyer specifically targeting the new-build market in France, the acquisition-side cost is closer to the UK SDLT figure on a primary residence than to the conventional French ancien rule of thumb.

UK SDLT, by contrast, does not materially distinguish between new and used residential property. There are small reliefs for shared-ownership and new-build leasehold purchases under specific schemes, but the headline rates are the same. The structural French preference for new-build acquisitions has no equivalent in the UK system.

The honest closing position

For a buyer choosing between markets at broadly comparable price points, the right summary is this: on a primary-residence purchase up to and around £500,000, UK SDLT is the cheaper acquisition (and dramatically so for first-time buyers); for a second home or non-resident purchase, France is the cheaper acquisition; for a new-build, France is dramatically cheaper. Above £1.5 million, the UK rates start to bite harder than the French ones, and the gap widens with property value. None of this should be the only consideration in choosing where to buy — ongoing holding costs, capital-gains treatment on disposal, financing availability, and the actual property market dynamics matter more in most cases than the headline transaction tax. But the transaction-tax differential is concrete, often material, and worth knowing before the deposit cheque is written.

The wider French context within which the acquisition decision sits — the step-by-step buying procedure, the LMNP regime if the property is to be let furnished, the annual non-resident tax return that follows the first year of letting, and the mechanics of the DMTO hike that drives most of the recent 0.5-percentage-point increase — all matter alongside the transaction-tax line. For most foreign buyers in France, the frais de notaire is a one-off rather than the dominant ongoing cost; what shapes the long-term economics is what happens after closing, not what happens at it.

Frequently asked questions

Is “frais de notaire” the same as “stamp duty”?

No. UK Stamp Duty Land Tax is a single tax payable to HMRC. French frais de notaire is a bundle of four items — DMTO and taxe de publicité foncière paid to the state, département and commune; the contribution de sécurité immobilière paid to the state cadastre service; the notary’s regulated emoluments; and pass-through débours. The notary collects all of them but keeps only the emoluments line — typically around 1.0 to 1.1% of the purchase price for an existing-build acquisition.

Why is the comparison so often miscalled “3% vs 7%”?

Because the 3% UK figure is the standard-residential SDLT rate on a primary-residence purchase at £500,000, while the 7% French figure is the all-in acquisition cost for an ancien. The two are not comparable: the 3% understates what most non-resident or additional-property UK buyers actually pay (which climbs to 8% or 10% with surcharges), while the 7% is the right all-in for the French side. The proper comparison matches buyer profile to buyer profile.

Does the UK 2% non-resident surcharge apply if I’m a British citizen working abroad?

Yes. The non-resident surcharge is decided by the SDLT day-count test — fewer than 183 days physically present in the UK during the twelve months before completion — not by nationality. A British citizen working in Dubai or Singapore who fails the day-count test triggers the surcharge just as readily as a foreign national would.

If I buy a Paris flat as a UK resident, do I pay any French acquisition surcharge?

No. France does not have an acquisition-stage non-resident surcharge equivalent to the UK 2%. A UK-resident buyer pays the same frais de notaire as a French-domiciled buyer of identical property. The cross-border tax differential for non-residents sits in the ongoing holding (social charges on rental income, taxe d’habitation surtax in certain communes) and the disposal (the non-resident plus-value régime under article 244 bis A CGI), not in the acquisition itself.

Are the frais de notaire on a French new-build really only 2%?

Yes, approximately. The taxe de publicité foncière on a qualifying new build (whether a completed property in its first five years or a VEFA off-plan purchase) is reduced to around 0.715% in lieu of the 5.81%-to-6.32% that the ancien attracts. The contribution de sécurité immobilière at 0.10% remains payable, and the notary’s emoluments and débours are unchanged. All-in, the frais de notaire on a €500,000 new build run around €10,000 to €11,000 — about 2.0 to 2.2%. Note that the purchase price itself includes 20% TVA paid to the developer, which is a separate consideration entirely.

What changed on 1 April 2025 in the UK, and what changed on 1 March 2026 in France?

On the UK side, 1 April 2025 marked the expiry of the COVID-era temporary nil-rate uplift: the residential nil-rate dropped from £250,000 back to £125,000, and the first-time-buyer relief tightened from £425,000 nil-rate (up to £625,000 maximum) back to £300,000 nil-rate (up to £500,000 maximum). On the French side, 1 March 2026 brought the new regulated notarial tariff under the arrêté of 25 February 2026, raising the four bands of property-sale emoluments from 3.870%/1.596%/1.064%/0.799% to 3.945%/1.627%/1.085%/0.814% — a modest uplift across the schedule, in force until 28 February 2028.