How to appeal a Welsh Land Transaction Tax decision
Appealing an LTT decision
WRA says you can ask it to review a tax decision or appeal directly to the independent tax tribunal.
- Act within 30 days of the letter’s issue date
- A review comes before any tribunal appeal
- Keep the decision letter and supporting papers
Scroll down for the full analysis.
Read the original guidance here:
How to appeal a Welsh Land Transaction Tax decision
If you think a Welsh Land Transaction Tax decision is wrong, act quickly. You may ask the Welsh Revenue Authority (WRA) to review it or, without first seeking a review, appeal directly to the tax tribunal. This is the Land Transaction Tax tax.
What this rule is about
The tax decision letter may state that WRA has reached a view you do not accept. The deadline matters because WRA says that, whether you choose a review or a direct appeal, you have 30 days from the letter’s issue date to challenge it. Act promptly.
What the official source says
WRA sets out two possible routes for challenging its decision. You may choose a review by WRA or go straight to the independent tax tribunal.
- Ask WRA to review its decision.
- Appeal directly to the independent tax tribunal.
- Take that step within 30 days of the letter’s issue date.
What this means in practice
If you ask WRA for a review, you must wait until that review ends, even if you later prefer the tribunal route, before appealing to the tribunal. You cannot run both routes at once.
- Keep the decision letter safe.
- Check the date WRA issued it.
- Decide whether you want a review or a direct appeal.
How to analyse it
Begin with the letter rather than the date on which you happened to read it. That difference can determine whether you are in time.
- Identify the decision you dispute.
- Find the letter’s issue date.
- Count the 30-day period from that date.
- Check whether a WRA review has already started.
Example
After receiving a tax decision letter, Sam asks WRA for a review within 30 days. While WRA carries out that review, Sam cannot begin a tribunal appeal.
Why this can be difficult in practice
In practice, people may focus on the date when they opened the letter. WRA’s guidance points instead to the date when it issued the letter. A review also puts the tribunal route on hold until it finishes.
- Do not assume the reading date starts the clock.
- Do not start a tribunal appeal during a WRA review.
- Keep proof of what you sent and when.
Key takeaways
- You have two possible routes to challenge a decision.
- The stated deadline is 30 days from issue of the letter.
- A WRA review must finish before a tribunal appeal starts.
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
- TCMA 2016 section 173 — asking WRA to review an appealable decision
- TCMA 2016 section 174 — time limit for requesting a WRA review
- TCMA 2016 section 178 — right to appeal an appealable decision
- TCMA 2016 section 179 — time limit for making a tribunal appeal
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
- The supplied source does not explain which types of tax decision can be appealed.
- The supplied source does not explain how WRA carries out a review or what happens after it ends.
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.
- The tax decision letter and its issue date
- The decision you disagree with
- Any papers that support why you think the decision is wrong
- A record of whether you have asked WRA for a review
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 How to appeal a Welsh Land Transaction Tax decision [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 - TCMA 2016 section 173 - asking WRA to review an appealable decision https://www.legislation.gov.uk/anaw/2016/6/section/173 - TCMA 2016 section 174 - time limit for requesting a WRA review https://www.legislation.gov.uk/anaw/2016/6/section/174 - TCMA 2016 section 178 - right to appeal an appealable decision https://www.legislation.gov.uk/anaw/2016/6/section/178 - TCMA 2016 section 179 - time limit for making a tribunal appeal https://www.legislation.gov.uk/anaw/2016/6/section/179 Guidance page from the Welsh Revenue Authority on this topic (guidance, not law): https://www.gov.wales/disagree-wra-tax-decision 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 - The supplied source does not explain which types of tax decision can be appealed. - The supplied source does not explain how WRA carries out a review or what happens after it ends. 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: How to appeal a Welsh Land Transaction Tax decision
Search Land Tax Advice with Google
