Land Transaction Tax: WRA’s 12-month enquiry period after a late return or amendment
WRA enquiry time limits
WRA normally has 12 months to open an enquiry into an LTT return. The starting date changes if you sent the return late or later amended it.
- WRA says it will notify you
- An authorised agent should also receive notice
- Keep records of returns and amendments
Scroll down for the full analysis.
Read the original guidance here:
Land Transaction Tax: WRA’s 12-month enquiry period after a late return or amendment
Land Transaction Tax: WRA's 12-month enquiry period after a late return or amendment
WRA can check your Land Transaction Tax return, Wales’s version of stamp duty, by opening an enquiry as part of its formal process for examining the return. It must tell you when it does this. The date matters because WRA normally has 12 months to open one.
What this rule is about
An enquiry is WRA’s formal check of a tax return. Opening one does not, by itself, say that you made a mistake. It means WRA has started its checking process.
What the official source says
WRA says it will notify you when it opens an enquiry, giving you notice that it has begun its formal checking process for the return concerned. It must notify you. If you have authorised an agent to act for you, WRA says it will notify that agent too when it opens an enquiry about your return. The agent must be authorised.
- WRA may open an enquiry within 12 months of the date you had to submit the return.
- If you sent the return late, the 12 months run from the date WRA received it.
- If you amend the return, WRA may open an enquiry within 12 months of that amendment.
What this means in practice
Keep a clear record of every return and change you make. The later date for a late return or amendment can give WRA a later period in which to start an enquiry.
- Keep proof of when you submitted the return.
- Keep a copy of every amendment.
- Make sure WRA has the right details for your authorised agent.
How to analyse it
Start with the return history. Do not assume the original submission date always decides the deadline.
- Identify the date you had to submit the return.
- Check whether WRA received it after that date.
- Check whether you later amended it.
Example
Pat had to submit a return on 1 June but sent it on 4 June. WRA may open an enquiry within 12 months of 4 June. If Pat later amends the return, that amendment can start a further 12-month period.
Why this can be difficult in practice
People often focus only on the original deadline. That can give the wrong answer where they sent a return late or later changed it. Dates and copies of notices can decide the point.
- A late return changes the starting date.
- An amendment also has its own 12-month period.
- An agent’s notification depends on their authority to act.
Key takeaways
- WRA will tell you when it opens an enquiry.
- Late returns use the date WRA received them.
- Amending a return can create a new enquiry period.
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 43 — time limit for opening an enquiry into a return
- LTTA 2017 Schedule 23 para 12 — LTT-specific changes to enquiry time limits
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, Tax assessments and enquiries guide: Opening an enquiry
Where this is not settled
- The supplied guidance does not explain what questions or documents WRA may request after opening an enquiry.
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 you had to submit the return.
- The date WRA received any late return.
- Dates of any changes to the return.
- Evidence that an agent had authority to act for you.
- Any notice that WRA sent about the enquiry.
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 can WRA open an LTT enquiry? [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 43 - time limit for opening an enquiry into a return https://www.legislation.gov.uk/anaw/2016/6/section/43 - LTTA 2017 Schedule 23 para 12 - LTT-specific changes to enquiry time limits https://www.legislation.gov.uk/anaw/2017/1/schedule/23/paragraph/12 Guidance page from the Welsh Revenue Authority on this topic (guidance, not law): https://www.gov.wales/wra-tax-assessments-enquiries-guide 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 guidance does not explain what questions or documents WRA may request after opening an enquiry. 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: WRA’s 12-month enquiry period after a late return or amendment
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