How can Scottish tax be levelled fairly on home based Scots and immigrant land owners alike

Checked on December 31, 2025
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Executive summary

A fair levelling of Scottish tax between home‑based Scots and immigrant landowners requires shifting tax weight toward land values, closing transactional loopholes, and reforming local property taxation while protecting productive uses — measures already under active review by Scottish authorities and advocates [1] [2] [3]. Any package must combine revenue design, enforcement co‑operation with UK institutions, and political measures to address obvious winners and losers [3] [4].

1. Diagnosing the imbalance: why current design advantages certain landowners

The problem rests in a tax system that taxes transactions (LBTT) and households (council tax) rather than the unimproved value of land, producing incentives for hoarding and generating uneven effective rates for owners versus residents; Scottish policy makers have explicitly framed a role for land‑value in future taxation to support diversification and regeneration [1]. At the same time the Scottish Government is reviewing LBTT and has adjusted supplements on additional dwellings — moves that affect second‑home and investor purchases but do not yet constitute a comprehensive land‑value regime [2] [5].

2. The core reforms: shift to land‑value and smarter transactional rules

A demonstrably fair approach would raise the role of land‑value taxation (LVT) as recommended by the Scottish Land Commission to discourage speculative holding and to fund community priorities such as town‑centre regeneration and a just transition to net zero [1]. Complementary reforms to LBTT — already scheduled for review in 2025 — can calibrate transaction charges and the additional dwelling supplement so that non‑resident or absentee purchases face genuine disincentives while exemptions protect active farming and affordable housing development [2] [5]. Those two levers together target both the flow (transactions) and the stock (land ownership) of unproductive holdings [1].

3. Practical implementation: data, revaluation and enforcement

To make LVT and reformed LBTT operational requires improved valuation bases and a modernised digital tax system: the Scottish Tax Strategy signals collaboration with HMRC on compliance and digitalisation, and the Scottish Budget process has committed reviews and staged implementation tools such as NDR balancing adjustments and targeted levies in specific sectors [3] [6]. Council tax revaluation and reform, repeatedly called for by parliamentary committees, must be sequenced with public engagement because rebanding will create clear “winners” and “losers” among homeowners and renters [4] [7].

4. Political economy and trade‑offs: winners, losers and hidden agendas

Taxing land value more heavily is politically sensitive; large estate owners and some rural interests will resist because structural concentration of ownership remains extreme and transformative measures threaten asset values — critics and reform advocates (including thinktanks urging local levies) frame this as necessary to break quasi‑feudal holdings [8]. Conversely, incremental tweaks to LBTT or increased supplements risk being presented as targeting “foreign” or “immigrant” owners for short‑term political gain without addressing domestic absenteeism or the complexity of cross‑border taxpayers — a point underscored by the Scottish Government’s need to coordinate with UK tax settings and legal frameworks [3] [2].

5. Safeguards, exemptions and fairness tests

Fairness requires explicit carve‑outs and graduated rates for productive uses — farming, community land trusts and social housing should face preferential treatment to avoid penalising economic activity, while vacant or derelict land attracts higher rates to encourage reuse [1]. Income tax remains a central part of overall progressivity: Scottish income tax bands and changes for 2025–26 show the government balancing progressive aims with political constraints, meaning property taxes must be designed to complement rather than replace income‑based redistribution [9] [10].

Conclusion: a staged, evidence‑led path to equality of treatment

Level‑playing requires a package: adopt land‑value elements, finish the LBTT review with stronger anti‑hoarding measures and targeted supplements, modernise valuation and digital compliance with HMRC, and conduct a transparent revaluation of local taxes with public consultation to manage distributional impacts [1] [2] [3] [4]. These steps preserve productive exemptions, tackle absentee ownership regardless of nationality, and bind reform to measurable outcomes such as land diversification and regeneration rather than headline‑driven scapegoating [1] [8].

Want to dive deeper?
What would a pilot land‑value tax look like in a Scottish council area and how have pilots performed elsewhere?
How could LBTT reform be designed to distinguish speculative investment from productive land use?
What legal and administrative challenges arise when Scotland coordinates land taxation with UK HMRC systems?