When separate farm land sales are not linked for Welsh LTT
Separate farm sales can be unlinked
The Welsh Revenue Authority’s example shows that a farmer’s later sale of land to the same neighbour was not linked to an earlier sale. The sales were independently marketed and were not part of one scheme, arrangement or connected series.
- Timing alone does not make sales linked.
- One wider plan can make separate sales linked.
- Documents and communications may decide the answer.
Scroll down for the full analysis.
Read the original guidance here:
When separate farm land sales are not linked for Welsh LTT
Two purchases of farm land are not linked simply because they involve the same seller and buyer. The central question is whether they were parts of a single plan.
That question can determine how Welsh land transaction tax, rather than stamp duty, applies. That is the consequence.
What this rule is about
Transactions count as linked when, taken together, they form one scheme, arrangement or series. The parties negotiate independently where the dealings are not linked.
The distinction matters. If purchases are linked, Welsh LTT considers the total paid for them before it apportions the tax between the purchases, rather than treating each purchase separately. This can change the tax outcome.
Timing matters, but it is not sufficient by itself.
What the official source says
Although Mr C put one field on the open market in 2020 and Ms D bought it, he marketed two further fields two years later while quietly reducing his farm before retirement. The Welsh Revenue Authority gives this example.
- Two years later, Mr C marketed two further fields.
- Ms D bought one of those fields.
- A land-holding company for a farming co-operative bought the other.
- Mr C’s sale to Ms D in 2020 and his sale to her in 2022 were not part of a single scheme or arrangement.
- They were not a series either, because they followed each other but had no connection.
On these facts, the official source says that the sales to Ms D are not linked.
What this means in practice
Welsh LTT considers each purchase that is not linked separately. For an unlinked purchase, the general LTT calculation uses the price paid for that purchase. It does not add that price to a separate sale.
- A later purchase from the same farmer is not automatically linked.
- A sale on the open market may point away from a pre-agreed wider plan.
- A buyer should not assume that a shared seller settles the answer.
- When purchases are linked, Welsh LTT uses the total paid across them.
How to analyse it
Start with the connection between the deals. Do not treat the number of months or years between them as decisive.
Then consider what the parties agreed, planned or expected when each sale occurred. Timing is only one clue.
- List every relevant sale, buyer and seller.
- Check whether the same people, or connected people, took part.
- Look for one plan to sell or buy several parcels of land.
- Check contracts, emails and marketing material for a link between sales.
- Ask whether the later sale was genuinely separate from the earlier one.
Example
Mr C puts a field on the open market and sells it to Ms D in 2020. In 2022, as part of his gradual retirement plans, he separately markets more land.
Ms D buys one field. The facts do not suggest that either party agreed the two sales together or included them in one plan. In the official example, the sales are separate for LTT purposes.
Why this can be difficult in practice
This is an area where people can make mistakes. The two-year gap helped show the facts in this case, but no period automatically prevents transactions from being treated as linked.
There is no safe gap. A short gap can still involve separate deals. A long gap can still form part of one arrangement.
- Private discussions may show a wider plan, even where sales happened later.
- One contract may refer to further land being sold later.
- Connected companies or family members can matter as much as the named buyer.
- Calling sales separate does not decide the issue if the documents show otherwise.
Key takeaways
- Same seller and buyer does not automatically mean linked sales.
- What matters is whether the sales formed one plan or connected series.
- Keep evidence showing why separate land sales were independent.
Technical analysis
For advisers, and for anyone who wants to check the law behind this page. You do not need this section to understand the guidance above.
Legislation
- LTTA 2017 section 8 — when land purchases count as linked transactions
- LTTA 2017 section 27 — calculating tax on a purchase that is not linked
- LTTA 2017 section 28 — calculating tax across linked land purchases
Official guidance
The pages below are the Welsh Revenue Authority’s guidance. Guidance is not law. It sets out how the Welsh Revenue Authority reads the legislation, and it is not binding on you, on a tribunal or on a court. Where guidance and the legislation differ, the legislation wins. the Welsh Revenue Authority can also change or withdraw guidance, and it may not cover your facts.
Where this is not settled
- There is no fixed time gap that automatically proves two land sales are, or are not, linked.
- Whether sales form one scheme, arrangement or series depends on the evidence and the connection between them.
Evidence you would need
This kind of case is decided on the facts of the individual property. These are the records that usually settle it, and the ones an adviser would ask you for.
- Sale dates and the land included in each sale
- Marketing details for each field or parcel
- Contracts, heads of terms and correspondence
- Evidence of any agreed plan to buy or sell several parcels
- Details of links between the parties involved
Explore this with an AI
Readers often want to test their own situation. Copy the prompt below into ChatGPT, Claude or Gemini. It hands the model the actual legislation for this page rather than letting it answer from memory, and tells it to be explicit about what is uncertain. What comes back is information, not advice – check it against the links above.
I am researching Land Transaction Tax (LTT), the tax on property in Wales. It replaced Stamp Duty Land Tax in Wales on 1 April 2018, and SDLT does not apply in Wales. MY QUESTION When separate farm land sales are not linked for Welsh LTT [Replace this with your own situation: what you are buying, the price, the dates, who the buyer is, and what you plan to do with the property.] THE LAW THIS TURNS ON - LTTA 2017 section 8 - when land purchases count as linked transactions https://www.legislation.gov.uk/anaw/2017/1/section/8 - LTTA 2017 section 27 - calculating tax on a purchase that is not linked https://www.legislation.gov.uk/anaw/2017/1/section/27 - LTTA 2017 section 28 - calculating tax across linked land purchases https://www.legislation.gov.uk/anaw/2017/1/section/28 Guidance page from the Welsh Revenue Authority on this topic (guidance, not law): https://www.gov.wales/land-transactions#5054 HOW I WANT YOU TO ANSWER 1. Work from the legislation above. Read it before answering. Guidance from the Welsh Revenue Authority is its view of the law, not the law, and does not bind a tribunal or a court. 2. Tell me what the rule actually requires, in plain English. 3. Tell me which facts decide the answer, and which facts would change it. 4. Tell me what evidence I would need to support the position. 5. Be explicit about anything unsettled or fact-sensitive. Do not guess. 6. Your training data has a cutoff and SDLT rates and reliefs change at fiscal events. Say so if you are not sure the law is current. POINTS ALREADY KNOWN TO BE UNCERTAIN ON THIS TOPIC - There is no fixed time gap that automatically proves two land sales are, or are not, linked. - Whether sales form one scheme, arrangement or series depends on the evidence and the connection between them. Do not give me a conclusion you cannot support from the provisions above.
Legislation links show the Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017 as it stood on 2025-11-17. The law may have changed since, and the rules that apply are those in force on the date of your transaction. The official guidance this page is based on is here.
This page was last updated on 3 September 2026
Useful article? You may find it helpful to read the original guidance here: When separate farm land sales are not linked for Welsh LTT
Search Land Tax Advice with Google
