LTT group relief: recovery of unpaid tax from others
Recovery after group relief withdrawal
WRA may recover unpaid LTT and interest from specified people other than the buyer after group relief is withdrawn.
- Potential targets include the seller, certain parent companies and controlling directors.
- The tax must be final and unpaid for six months.
- The notice is subject to a three-year limit.
Scroll down for the full analysis.
Read the original guidance here:
LTT group relief: recovery of unpaid tax from others
If group relief is withdrawn and the buyer does not pay the resulting Welsh stamp tax, Land Transaction Tax (LTT), WRA may pursue other people in the group. That can include the seller, a parent company or a controlling director. The point can be costly.
What this rule is about
Group relief may remove LTT from land transfers between companies in the same group. It may later be withdrawn. When that happens, tax can become due on the earlier transfer.
The buyer is not always the only person WRA can approach. The law creates a back-up recovery route when that tax remains unpaid.
What the official source says
WRA’s technical guidance says it must serve a notice on the person from whom it wants to recover the money. The guidance describes what that notice must do.
- It must state the amount the person must pay.
- It requires payment within 30 days of service.
- WRA must serve it within three years of the tax being finally determined.
- It covers unpaid tax and interest on that tax.
- The guidance says it has effects for recovery and appeals.
Under the supplied legislation, this route starts only when the amount is final and remains unpaid for six months after its due date. For group relief, once those conditions are met and the statutory recovery route is available, WRA may issue a notice to the seller, certain companies above the buyer, or certain controlling directors. The notice allows recovery.
What this means in practice
Outsiders can still face recovery. A notice can make the named person responsible for the unpaid amount.
- A seller may receive a notice after group relief is withdrawn.
- A parent company may be at risk if it was above the buyer.
- A director can be at risk through control of the buyer or its parent.
- Interest may be included with the unpaid LTT.
- Someone who pays can recover that amount from the buyer.
How to analyse it
Start with the unpaid tax, not the group chart. Then work through the timing and the people WRA may name.
- Was group relief withdrawn on the land transfer?
- Has the amount of LTT been finally determined?
- Has it remained unpaid for six months after it was due?
- Who sold the land to the buyer?
- Which companies sat above the buyer during the relevant period?
- Who was a controlling director during that period?
- Does the notice state the amount and meet the time limit?
Example
Imagine Group A transfers land to its subsidiary, BuildCo, using group relief. Relief is later withdrawn and BuildCo does not pay the final LTT bill. Six months pass. WRA may serve a recovery notice on the seller, a qualifying parent company or a controlling director. If the parent pays the amount and interest, it may recover that money from BuildCo.
Why this can be difficult in practice
The hard part is often working out who was in the right role at the right time. Group charts can change quickly. Control can also be less obvious than a job title suggests.
- Do not assume only the buyer can be asked to pay.
- Do not treat a current group chart as the whole answer.
- Keep records of ownership, directorships and control.
- Check the final tax decision and payment history.
- Check the notice date carefully against the three-year limit.
Key takeaways
- Unpaid LTT after group relief withdrawal can be recovered from other people.
- The notice must name the amount WRA seeks.
- A person who pays may recover the amount from the buyer.
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 16 para 13 — who may be required to pay unpaid group relief tax
- LTTA 2017 Schedule 16 para 14 — notices for recovering unpaid group relief tax
- LTTA 2017 Schedule 17 para 8 — who may pay unpaid reconstruction or acquisition relief tax
- LTTA 2017 Schedule 17 para 9 — notices for recovering unpaid reconstruction or acquisition relief tax
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 WRA guidance and the bundled statutory wording differ on whether the notice is served or issued, when the 30-day period begins, and how its legal effect is described.
- The requested currency notice was not present in the mounted skills. The current legal position and any relevant commencement changes need checking before reliance.
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 original group relief transaction and the date it took effect
- the event that caused group relief to be withdrawn
- the final determination of the tax amount
- evidence of when the tax became payable and what remains unpaid
- the group chart and ownership history
- evidence of any director’s control of the buyer or its parent company
- the recovery notice, its issue or service date, and the amount stated
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 LTT group relief: recovery of unpaid tax from others [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 16 para 13 - who may be required to pay unpaid group relief tax https://www.legislation.gov.uk/anaw/2017/1/schedule/16/paragraph/13 - LTTA 2017 Schedule 16 para 14 - notices for recovering unpaid group relief tax https://www.legislation.gov.uk/anaw/2017/1/schedule/16/paragraph/14 - LTTA 2017 Schedule 17 para 8 - who may pay unpaid reconstruction or acquisition relief tax https://www.legislation.gov.uk/anaw/2017/1/schedule/17/paragraph/8 - LTTA 2017 Schedule 17 para 9 - notices for recovering unpaid reconstruction or acquisition relief tax https://www.legislation.gov.uk/anaw/2017/1/schedule/17/paragraph/9 Guidance page from the Welsh Revenue Authority on this topic (guidance, not law): https://www.gov.wales/land-transaction-tax-group-relief-technical-guidance#6211 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 WRA guidance and the bundled statutory wording differ on whether the notice is served or issued, when the 30-day period begins, and how its legal effect is described. - The requested currency notice was not present in the mounted skills. The current legal position and any relevant commencement changes need checking before reliance. 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: LTT group relief: recovery of unpaid tax from others
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