Around 156,000 homes in England are expected to pay the high value council tax surcharge from April 2028 on the Office for Budget Responsibility’s estimate, and the OBR provisionally assumes one in five owners will challenge their band, with 40% of those challenges succeeding.
Those challenges turn on comparable evidence – achieved sale prices, not asking prices – and the consultation proposes that estimates from estate agents and property listing websites be inadmissible. Bands will be set on 2026 values, which means the evidence that sets a client’s band until 2033 is being created this year. The Budget on 28 October may change who is caught. It will not change what settles a challenge.
What it costs, and where the four cliff edges fall
The shape of this is already familiar to most agents: a flat annual surcharge bolted onto council tax in England, announced in the Autumn Budget 2025 and consulted on between 19 May and 14 July 2026, in four bands. The table is here for reference.
| Property value | Annual surcharge |
|---|---|
| £2m to £2.5m | £2,500 |
| £2.5m to £3.5m | £3,500 |
| £3.5m to £5m | £5,000 |
| Over £5m | £7,500 |
Liability falls on the legal owner rather than the occupier, which captures freeholders, leaseholders whose lease was originally granted for more than 21 years, companies and trustees. First bills land in March 2028 for the April 2028 start, and the Treasury expects to take around £430m a year from 2028/29.
The design matters more than the headline. These are slab charges, not marginal ones, so there are four cliff edges rather than one. A property valued at £2,499,000 pays £2,500. A property valued at £2,500,000 pays £3,500. One thousand pounds of value costs a thousand pounds a year, every year, indexed.
How will the mansion tax be valued?
Mostly by automated valuation model. The Valuation Office Agency (VOA), which sits within HMRC, will run what the consultation calls a model-assisted valuation approach, combining AVMs with professional valuer judgement, drawing on property databases, stamp duty records, local authority planning records and geospatial data. Press reports in February 2026 put VOA recruitment at up to 1,000 officials, though the agency did not confirm a figure at the time and HMRC has since said most of those hires will not work on the surcharge.
Two dates decide everything. Properties will be assessed at their estimated market value in 2026 – this year – and the list will then be revalued on a five-yearly cycle, with the next revaluation in 2033. Note the gap. A band set on 2026 evidence governs the five charging years from April 2028 to March 2033, so 2026 evidence is still setting bills seven years after the valuation. Improvements made after the valuation date do not feed into the band until the revaluation.
AVMs are not the weak link they are sometimes assumed to be. Lenders rely on them for mortgage valuations, and for a national exercise covering millions of homes they are the only practical method. Their limits are narrower and more specific than that: thin comparable evidence, properties that are unique or heavily altered, and markets moving faster than the data behind them.
Prime London above £2m is where all three overlap. Average achieved prices across prime London fell 7.9% in the year to July 2026, and in Q2 2026 prime London recorded its largest annual fall in achieved prices since 2009, down 7.5%, with prime central London down 9.0%.
Source: LonRes. Data to 31 July 2026 and to 30 June 2026.The consultation’s own design reflects that, pairing the model with professional valuer judgement and reserving inspections for cases where comparable evidence is thin. So does the OBR, which has budgeted for one in five owners to challenge their band and 40% of them to win. Neither the consultation nor the OBR assumes the model will be right every time at this end of the market.
The consultation does not say whose model it will be. The VOA may license an established AVM or build its own, and either way the model it picks will matter more to a prime London valuation than the rate does. Worth watching for in the consultation response, and we will cover it in the newsletter when it lands.
Will a valuation officer inspect your client’s home?
Most will not. A Sunday Telegraph report at the end of August said valuation officers would carry out in-person interior inspections of properties near the £2m threshold, assessing room counts, storeys, bedrooms and bathrooms. HMRC narrowed it on 24 August, saying most valuations will be made without a home visit, using publicly available data, third-party data and satellite imagery, with internal inspections only where attributes can only be confirmed internally or a re-measurement is required.
Powers of entry are neither new nor unusual here. Section 25A of the Local Government Finance Act 1992 has allowed a valuation officer to enter a dwelling since 2015, subject to First-tier Tribunal approval and at least three clear days’ written notice.
A letter from the Valuation Office Agency is not an accusation and not an emergency. Most bands will be set without anyone visiting. Where a visit does happen it needs tribunal approval and three clear days’ notice, and the penalty attaches to obstructing the officer rather than to disagreeing with the outcome. The useful preparation is not a locked door. It is having the comparable evidence ready before the band is set.
Which is the whole point. An inspection establishes what the house is. It does not establish what houses like it sell for. That second question is the one that moves a band, and it is answered by achieved prices.
Why the appeals are an evidence problem, not a tax problem
Because the tax is fixed and the valuation is not. Owners will be able to challenge both their valuation and their liability, with an initial eight-month challenge window at launch and six months thereafter, and appeals heard by the Valuation Tribunal for England. Taxpayers keep paying while a dispute runs and are refunded if it is reversed.
The OBR’s own assumption tells you what the government expects. Applied to 156,000 properties, it implies in the order of 31,000 challenges and 12,000 reductions. Each one is decided on comparables.
The proposal that has had least attention is this one. The consultation proposes that estimates from estate agents or property listing websites be inadmissible as evidence in a challenge. Propertymark has criticised that exclusion, arguing that agents hold exactly the local knowledge the exercise depends on.
Property agents have expertise in local areas, about comparable properties, assessing home renovations and improvements, and unique characteristics of properties which are likely to feature in areas where property is valued above £2 million.
The distinction being drawn is between an opinion and a record. An agent’s estimate is an opinion. An achieved sale price on a comparable property is a record. The first would be ruled out; the second is the evidence the assessment is built on.
A formal challenge will usually be argued by a chartered valuer or surveyor. The comparable evidence it rests on is the agent’s to supply, and the agent who supplies it is in the room.
How the market has already moved around £2m
Not gently, and not evenly. Several research desks have published on the surcharge; the pricing-behaviour figures below are Hamptons’ own. David Fell found that 83% of offers on homes priced within 10% of £2m kept the price beneath the threshold, against 64% a year earlier, while behaviour around the £1m mark – outside the tax – remained unchanged. That second finding is the useful control: it points to the tax rather than the wider market. The three figures below are counts of homes coming to market, not price movements.
Both sides have an interest in a price that sits below the line. The buyer carries the charge once they own it, and the seller knows a sub-threshold asking price reaches a wider pool. The negotiation is not over whether to stay under. It is over who absorbs the difference, and that is a live conversation on every instruction within reach of a threshold. It is being had against a market where more than half of prime London sales in July 2026 completed after at least one price reduction, the average discount to asking price was 10.4%, and homes taking more than 12 months to sell gave up 19.3% against 3.9% for those selling inside three months.
Source: LonRes Prime London Market Dashboard, August 2026. Data to 31 July 2026.The market can better adapt to changes when it is functioning strongly, which is not the case right now.
Will the mansion tax go up in the Budget on 28 October?
Nobody outside the Treasury knows. But the direction of travel is not subtle. Andy Burnham took office as Prime Minister on 20 July 2026 with John Healey as Chancellor, and the Mail on Sunday reported in July that the threshold could drop from £2m to £1.5m. Nothing has been announced, and the consultation response has not been published.
Tax Policy Associates and Hamptons have both modelled the effect, on different baselines, so read them as direction rather than arithmetic. Tax Policy Associates has roughly 127,000 properties in scope becoming roughly 243,000, close to a doubling. Hamptons, analysing its own proprietary data, estimates the increase at 102% across England, 79% in London and between 150% and 180% across the Midlands and the North.
Knight Frank made the regional point from the other direction in analysis published before the Autumn Budget 2025, calculating the threshold that would capture an equivalent share of stock in each region: £829,000 across London as a whole, £408,000 in the West Midlands and £288,000 in the North East. Its analysis covered Great Britain; the surcharge applies in England only.
Read those percentage increases carefully, though. They look dramatic outside London because the base is so small, not because the tax is about to reach the suburbs.
Even at a £1m threshold, and excluding London and the South East, we are talking about less than 1% of the national market.
Which is the point worth holding onto. Lowering the threshold widens the tax politically and adds a great many more homes in absolute terms. It does not stop this being a London and South East tax.
Tom Bill, head of UK residential research at Knight Frank, has said that if the Budget brings a broader package of asset and wealth taxes, the current bands “may prove to be merely introductory rates”. He warns that a third successive Budget targeting high-value property, after 2024 and 2025, could set back any recovery.
There is precedent for the drift, and the profession has put it on the record. Hannah Catt, senior associate in private property at Charles Russell Speechlys, notes that the annual tax on enveloped dwellings began as a charge on property above £2m in 2013 and now starts at £500,000, and warns of mission creep: “If the surcharge can be implemented with relative ease, there is a real risk of mission creep.” She also points out that council tax bands themselves have not been updated since 1991.
Stamp duty is the other lever. Burnham ruled out scrapping it on 27 July, though the trade is not treating that as settled.
While the PM has ruled out scrapping stamp duty this year, it’s not inconceivable that the topic could come up again at a later stage.
The concentration is the political problem. Kensington and Chelsea council calculates that four London boroughs – itself, Westminster, Richmond upon Thames and Wandsworth – would contribute around £270m, more than half the national bill. The parliamentary constituency of Cities of London and Westminster alone accounts for an estimated 10.5% of the surcharge, on PolicyEngine’s modelling of a £400m yield. A tax this geographically concentrated is politically exposed in both directions.
Who pays the mansion tax on a rented property?
The owner, which in practice means the landlord. Propertymark has asked for landlords to be able to choose whether they or their tenants carry the charge, mirroring the flexibility that already exists in council tax, but as drafted the liability sits with the legal owner regardless of who lives there.
A £2m-plus rental property acquires a £2,500 to £7,500 annual cost with no rent attached to it. Prime central London rents rose 5.7% in the year to July 2026, the strongest growth in 18 months, and almost one in eight prime London lets so far in 2026 exceeds £100,000 a year – the point at which a tenancy falls outside the Renters’ Rights Act. Expect the surcharge in rent review conversations from 2027, and expect to evidence those reviews.
What agents should do before March 2028
Four things, none of which require the legislation to be finalised.
Identify the exposure
Any client above roughly £1.8m is either in scope or close enough to a threshold that the charge belongs in the pricing conversation. If the reported £1.5m threshold ever arrives, that list extends further down. Either way it is a call list, not a worry.
Build the evidence file now
The valuation basis is 2026. Achieved comparables from this year are what will settle a 2028 challenge, and they will be considerably harder to assemble in eighteen months’ time than they are today.
Price into the thresholds
On any instruction within 10% of £2m, £2.5m, £3.5m or £5m, the threshold is a negotiating fact. Bring the achieved evidence to the market appraisal and you set the frame.
Get ahead of the letter
Clients will read the inspection headlines before they read the guidance. Be the person who explains the notice period, the tribunal approval and what actually changes a band.
The Budget will decide how many people this tax reaches. Comparables will decide what each of them pays.
Where LonRes fits
Every argument above resolves to the same question: what did comparable property actually sell for. Asking prices do not answer it. The consultation would rule portal estimates out as evidence. A model will produce a number, and whether you accept that number or challenge it, you need the same thing to judge it.
LonRes holds achieved sale prices across prime London, alongside the Sales Archive that lets you build a comparable set by street, period, size and date rather than by postcode alone. Live Sales shows what is trading now, including off-market stock that does not appear on the portals. This is the gap LonRes was built to close.
The agents who spend the next eighteen months quietly building evidence files for their £2m-plus clients will own those relationships when the band notices arrive. The ones who wait for the legislation will be starting where everyone else starts.
Achieved sale prices, not asking prices. The evidence a valuation challenge is actually decided on.
Build a comparable set by street, period, size and date across prime London, and see what is trading now – including off-market stock the portals never see.
Start your free trial →Frequently asked questions
What is the mansion tax and when does it start?
The mansion tax is the high value council tax surcharge, an annual charge on residential property in England valued at £2m or more. It takes effect in April 2028, with first bills issued in March 2028. Charges run from £2,500 to £7,500 a year depending on value and rise with CPI from 2029/30.
How will properties be valued for the mansion tax?
The Valuation Office Agency will use automated valuation models combined with professional valuer judgement, drawing on sales, stamp duty, planning and geospatial data. The consultation does not name the model. Values are assessed as at 2026, and because charging begins in April 2028 the first band runs on 2026 evidence until the 2033 revaluation.
Will HMRC inspect my home for the mansion tax?
Possibly, but most bands will be set without a visit. HMRC said on 24 August 2026 that it will rely mainly on publicly available data, third-party data and satellite imagery, inspecting internally only where attributes cannot be confirmed any other way. Entry requires First-tier Tribunal approval and at least three clear days’ written notice.
Can a mansion tax valuation be appealed?
Yes. Owners can challenge their valuation or their liability, with an initial eight-month challenge window at launch and six months afterwards, and appeals heard by the Valuation Tribunal for England. The Office for Budget Responsibility provisionally assumes one in five owners will appeal and that 40% will succeed. Payment continues during a dispute.
Who pays the mansion tax on a rented property?
The legal owner, not the tenant. That includes freeholders, leaseholders whose lease was originally granted for more than 21 years, companies and trustees. Propertymark has asked for landlords to be allowed to pass liability to tenants as they can with council tax, but that flexibility is not in the current proposals.
Will the mansion tax threshold be lowered to £1.5m?
It has been reported but not announced. The Mail on Sunday said in July 2026 that the threshold could fall from £2m to £1.5m, which Tax Policy Associates estimates would take properties in scope from around 127,000 to around 243,000. Any change would be expected at the Budget on 28 October 2026.
This article is editorial comment on published proposals, not tax, legal or valuation advice. Clients should take professional advice on their own position.
Sources
- Band structure, valuation method, liability, the evidence-sharing proposal and appeal windows — High Value Council Tax Surcharge: design and delivery, Ministry of Housing, Communities and Local Government consultation, 19 May to 14 July 2026: gov.uk
- Properties in scope (c.156,000), revenue forecast (£430m from 2028/29) — House of Commons Library, High Value Council Tax Surcharge and homes over £2 million: commonslibrary.parliament.uk
- CPI uprating from 2029/30 and owner liability — Deloitte Taxscape, Autumn Budget 2025 measures: taxscape.deloitte.com
- Propertymark comment on the consultation and Nathan Emerson quote, 20 May 2026: propertymark.co.uk
- Landlord and tenant liability debate, July 2026 — Letting Agent Today: lettingagenttoday.co.uk
- February 2026 press reporting of VOA recruitment at up to 1,000 officials, and HMRC’s later statement that most of those hires will not work on the surcharge — HomeOwners Alliance: hoa.org.uk
- In-person interior inspections near the £2m threshold, Sunday Telegraph report, 23 August 2026 — Estate Agent Today: estateagenttoday.co.uk
- Entry powers and the obstruction penalty under section 25A of the Local Government Finance Act 1992, tribunal approval and three clear days’ notice, and HMRC’s statement on publicly available data, third-party data and satellite imagery, 24 August 2026: calculatemystampduty.co.uk
- HMRC confirmation that most surcharge decisions will be made without home visits, 24 August 2026 — Mortgage Solutions: mortgagesolutions.co.uk
- OBR appeal assumptions (20% appeal rate as a central estimate, 40% success rate provisionally assumed) and the 156,000 post-behavioural figure — Office for Budget Responsibility, supplementary forecast information: obr.uk
- Regional threshold equivalence (£829,000 London, £408,000 West Midlands, £288,000 North East), 3 November 2025 — Knight Frank, reported by Estate Agent Today: estateagenttoday.co.uk
- Pricing behaviour around £2m and £5m and the £1m control group, David Fell, February 2026 — Hamptons: hamptons.co.uk
- Threshold reduction impact (102% England, 79% London, 150–180% Midlands and north), July 2026 — Hamptons: hamptons.co.uk
- Properties in scope at a £1.5m threshold (127,000 to 243,000), 7 July 2026 — Tax Policy Associates: taxpolicy.org.uk
- Reported £1.5m threshold and political context, 8 July 2026 — MoneyWeek: moneyweek.com
- Tom Bill on “introductory rates” and three successive budgets, 18 August 2026 — The Negotiator: thenegotiator.co.uk
- Four boroughs contributing around £270m, over half the national bill, 6 August 2026 — Royal Borough of Kensington and Chelsea: rbkc.gov.uk
- Constituency-level revenue shares (Cities of London and Westminster 10.5%) — PolicyEngine: policyengine.org
- ATED threshold precedent (£2m to £500,000), the “mission creep” warning and the 1991 council tax band date, Hannah Catt, senior associate in private property at Charles Russell Speechlys, 19 February 2026 — Tax Adviser: taxadvisermagazine.com
- Budget date of 28 October 2026, prime minister and chancellor — BKL: bkl.co.uk
- Prime London achieved prices (−7.9% annual), discounts (10.4%), reductions, time on market and prime central London rents (+5.7%, strongest in 18 months) — LonRes Prime London Market Dashboard, August 2026, data to 31 July 2026: lonres.com
- Q2 2026 price fall (−7.5%, largest since 2009), prime central London (−9.0%), lets above £100,000 a year and the Renters’ Rights Act threshold (almost one in eight prime London lets), Nick Gregori and Anthony Payne quotes — LonRes Prime London Market Update, Summer 2026, data to 30 June 2026: lonres.com