Splitting a property price fairly for Welsh Land Transaction Tax
Fairly splitting a purchase price
A single price may cover a property, movable items, a business or land in different places. For LTT, the part paid for land must be worked out on a just and reasonable basis.
- Contract labels do not decide the answer.
- Movable items and fixed items are treated differently.
- Keep evidence for every value used.
Scroll down for the full analysis.
Read the original guidance here:
Splitting a property price fairly for Welsh Land Transaction Tax
Splitting a property price fairly for Welsh Land Transaction Tax
When a single agreed price covers a property and other items, you may need to divide it before calculating Welsh Land Transaction Tax (LTT), Wales’s version of stamp duty. The division must be fair and sensible. A contract figure does not decide the issue by itself.
What this rule is about
Home sales usually have one price. That price covers the house and land. Deals can include more than property. They may include movable furniture or white goods, a business, or land in more than one place, so the overall price can cover property and other things. Some of the price may not relate to land.
The law describes the amount relevant to the land purchase as “chargeable consideration”. Put simply, it is the amount paid for the land.
Why does this matter? Including too much may increase the amount used to calculate LTT. Excluding too much may make the return incorrect.
What the official source says
Where one overall price covers two or more property purchases, combines a property purchase with something else, or partly relates to matters that count and partly to matters that do not, Schedule 4 requires a just and reasonable split. That is the requirement.
The Welsh Revenue Authority’s technical guidance provides common examples. It is guidance, not the law itself. It explains how the authority applies the statutory rule.
- A price may include movable fixtures and fittings, including curtains, furniture, white goods or plants in pots, where they are included with the house and land in the same bargain. That can matter.
- Items fixed to the property, such as fitted furniture, sinks, baths and central heating, are not treated in the same way.
- A business sale may include land, goodwill, plant, machinery and stock under one overall price.
- Land may be in Wales and elsewhere, creating a need to split the price fairly.
- Growing trees and fruit on them are part of the land.
- Growing crops are also part of the land under the official source.
- Harvested crops, felled trees and plants in pots are not part of the land.
The central point is that the actual bargain outweighs the paperwork. Even if a contract states separate prices, the law treats a bargain that is substantively one deal as covering every part of it.
What this means in practice
You cannot reduce the amount used for LTT merely by assigning a high value to household items. The amount given to those items must reflect their genuine value as movable items.
That does not mean you must always disregard movable items. It means the evidence must support the amount.
- Keep a clear list of every item included in the sale.
- Separate movable items from things attached to the property.
- Use realistic values for movable furniture and appliances.
- Keep records that explain how you reached those values.
- For a business, identify the shares of the total price for land, stock, machinery and goodwill.
- For land across borders, identify the land in Wales and the land elsewhere.
People often make mistakes here: an item is not movable merely because it is described as “furniture”. A fitted kitchen unit forms part of the property. A free-standing table does not.
How to analyse it
Begin with the entire deal, rather than merely the property contract, and consider whether everything received for the total price matches the figures stated in the documents. Do that first.
- Is there one overall bargain, even if there are separate documents or prices?
- Does the price cover one property purchase or two or more?
- Does it cover land and non-land items together?
- Which items are physically attached to the property?
- Which items can be removed without being part of the building or land?
- If a business is included, what evidence supports each part of the price?
- Does any part of the land lie outside Wales?
- Is the proposed split fair when viewed against the actual facts?
In other words, do not start with the tax outcome you want. Start with what was actually bought and the value of each part.
Example
Leila agrees to pay £400,000 for a house. The sale includes free-standing furniture and appliances worth £5,000, supported by an itemised list and realistic values that show the amount is separately attributable within the agreed price. The evidence matters. As an illustration, a fair split could leave £395,000 as the part paid for the house and land, and £5,000 for the movable items.
Change one fact and the result may differ. A £5,000 list may include fitted cupboards, a sink and central heating equipment. Those items are part of the property. Treating their value as payment for separate movable goods would not be fair.
Why this can be difficult in practice
No fixed percentage applies. This includes furniture, business assets or land outside Wales. The test deliberately depends on what is fair in the circumstances. Evidence therefore matters.
You may think an agreed contract split is sufficient. It is not. The law permits the price to be reworked if it was not divided fairly.
- Some items are hard to classify as fixed or movable.
- Second-hand values may be lower than the amount originally paid.
- A business price may reflect several assets that are hard to value separately.
- Cross-border land can require careful plans and title evidence.
- A paper allocation that does not fit the facts may be challenged.
Key takeaways
- Split a single price fairly where it covers land and other things.
- Facts and realistic values matter more than contract labels.
- Keep evidence showing what was included and why the split is fair.
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 Schedule 4 para 1 — what counts as payment for a land purchase
- LTTA 2017 Schedule 4 para 4 — fairly splitting payment between parts of a deal
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.
- Welsh Revenue Authority, Chargeable consideration technical guidance, LTTA/2330: Just and reasonable apportionment
Where this is not settled
- There is no fixed percentage or valuation formula for a fair split. What is just and reasonable will depend on the evidence.
- The supplied statutory text is marked as introduced and no currency-notice.md was available in the mounted skills. The current wording should be checked before relying on it for a later transaction.
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 sale contract and any list of included items
- Photographs and inventories showing what was included
- Evidence supporting the value of movable items
- Business accounts or valuations where goodwill, stock or machinery are included
- Plans and title documents where land is in Wales and elsewhere
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 Splitting a property price fairly for Welsh Land Transaction Tax [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 Schedule 4 para 1 - what counts as payment for a land purchase https://www.legislation.gov.uk/anaw/2017/1/schedule/4/paragraph/1 - LTTA 2017 Schedule 4 para 4 - fairly splitting payment between parts of a deal https://www.legislation.gov.uk/anaw/2017/1/schedule/4/paragraph/4 Guidance page from the Welsh Revenue Authority on this topic (guidance, not law): https://www.gov.wales/chargeable-consideration-technical-guidance#5125 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 percentage or valuation formula for a fair split. What is just and reasonable will depend on the evidence. - The supplied statutory text is marked as introduced and no currency-notice.md was available in the mounted skills. The current wording should be checked before relying on it for a later transaction. 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: Splitting a property price fairly for Welsh Land Transaction Tax
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