Land transaction tax: late review requests need a reasonable excuse and no unreasonable delay
Late WRA review requests
The WRA may consider a late request where you had a reasonable excuse and acted without unreasonable delay after it ended.
- Explain the missed deadline
- Show what happened after the excuse ended
- Act promptly if you need to apply to the tribunal
Scroll down for the full analysis.
Read the original guidance here:
Land transaction tax: late review requests need a reasonable excuse and no unreasonable delay
Land transaction tax: late review requests need a reasonable excuse and no unreasonable delay
Missing the deadline to ask the WRA to review a tax decision does not always end the matter. The WRA may still look at it if you had a reasonable excuse and acted without unreasonable delay once that excuse ended.
What this rule is about
A review is a way of asking the Welsh Revenue Authority, or WRA, to look again at one of its decisions. This is relevant when you think a land transaction tax decision is wrong but sent your request late.
Being late is not enough on its own. Explain why it happened. Act promptly when you can.
That second part matters. A good reason at first may not explain a long wait later.
What the official source says
The Welsh Government guidance says the WRA will consider a late request only where it is satisfied about two things. These are separate conditions, so meeting one does not automatically meet the other.
- You had a reasonable excuse for not sending the review request within the time limit.
- You sent the request without unreasonable delay after that excuse stopped applying.
- The WRA will write to tell the person asking whether it will carry out the review.
If the WRA refuses to review the decision, seek permission from the tribunal. Your application must explain why the review request was late.
The tribunal also considers timing. You must apply without unreasonable delay.
- There must have been a reasonable excuse for the late review request.
- The request to the WRA must have followed without unreasonable delay after the excuse ended.
- The application to the tribunal must also have been made without unreasonable delay.
If the tribunal accepts the application and tells the WRA to review the decision, the WRA must carry out that review.
What this means in practice
Do not assume that a missed deadline makes your position hopeless. Equally, do not assume that explaining the first delay is enough. The timeline after the problem ends is part of the test.
For example, an illness may explain why you could not deal with the request at first. It may not explain a further delay after you were able to act.
- Write down the date the deadline expired.
- Set out what stopped you from sending the request on time.
- Identify when that problem ended or became manageable.
- Send the request as soon as you can after that point.
- Keep records that support the dates in your explanation.
The official source does not set a fixed number of days that will always be acceptable. It uses the phrase “unreasonable delay”, so the facts and the sequence of events matter.
How to analyse it
Start with dates, not broad claims. A short and clear timeline will usually show the real issue.
- What decision did you want the WRA to review?
- When did the normal period for asking for that review end?
- Why could you not send the request in time?
- Why was that reason a reasonable excuse in your circumstances?
- When did the excuse stop applying?
- What did you do between that date and the date you sent the request?
- If the WRA refused, when did you apply to the tribunal?
Answer each question with dates and documents where possible. A vague account can make it hard to see whether there was avoidable delay.
Example
Imagine that Mari misses the deadline for asking the WRA to review a decision. She explains that a serious problem stopped her dealing with it. Once that problem ends, she sends her request promptly and includes a timeline. The WRA will consider whether those facts show both a reasonable excuse and no unreasonable delay.
Now change one fact. Mari waits for a substantial period after the problem has ended, without explaining why. Her original reason may still have been genuine, but the later wait may cause difficulty.
Why this can be difficult in practice
The key words are not defined in the supplied guidance. “Reasonable excuse” and “unreasonable delay” need a judgment about what happened, when it happened, and what you could realistically have done.
- People may explain why they first missed the deadline but not the time that followed.
- A reason can stop applying before all practical problems have disappeared.
- Waiting after a WRA refusal can create a separate issue for a tribunal application.
- The WRA guidance describes its approach; the current legislation should also be checked for the rules in force at the relevant time.
Three periods may need explanation: the missed deadline, the time before the late request, and, if needed, the time before the tribunal application.
Key takeaways
- A late request may still be considered.
- You need a reasonable excuse and prompt action afterwards.
- If the WRA refuses, a tribunal application has its own delay test.
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.
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
- Whether an excuse is reasonable, and whether any delay is unreasonable, depend on the facts.
- The supplied statutory bundle does not contain the Tax Collection and Management (Wales) Act 2016 provisions on reviews and appeals.
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 date by which the review request should have been sent
- The date the request was actually sent
- A clear account of what caused the delay
- Evidence showing when that problem ended
- The date of any application to the tribunal
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 Late request for a WRA review: when it may be accepted [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.] Guidance page from the Welsh Revenue Authority on this topic (guidance, not law): https://www.gov.wales/tax-collection-and-management-wales-act-2016-reviews-and-appeals-technical-guidance#6628 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 - Whether an excuse is reasonable, and whether any delay is unreasonable, depend on the facts. - The supplied statutory bundle does not contain the Tax Collection and Management (Wales) Act 2016 provisions on reviews and appeals. 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: Land transaction tax: late review requests need a reasonable excuse and no unreasonable delay
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