LTT: When the Welsh Revenue Authority can share your tax information
Sharing LTT taxpayer information
WRA guidance says protected taxpayer information may be shared only in defined circumstances, such as running WRA services, legal proceedings, crime prevention, court orders and cooperation with other tax bodies.
- Consent is one route, but not the only route.
- WRA says it considers proportionality and the public interest.
- Unlawful disclosure can be a criminal offence.
Scroll down for the full analysis.
Read the original guidance here:
LTT: When the Welsh Revenue Authority can share your tax information
LTT: when WRA can share your tax information
The Welsh Revenue Authority, or WRA, holds information when it deals with Land Transaction Tax (LTT). It cannot simply pass that information on because somebody asks for it. Its guidance says WRA may share information only in set situations, and it must consider whether the step is proportionate and in the public interest.
What this rule is about
Tax information often concerns individuals. It may explain a property purchase, a payment, or contact with WRA. The guidance calls it protected taxpayer information, or PTI.
Confidentiality is the starting point. Yet WRA still needs to run LTT and work with other bodies in some cases. The guidance sets out where that can happen.
Some sharing may take place without consent when the stated purpose fits a permitted route, the proposed recipient and scope fit that route, and WRA considers the step proportionate and in the public interest. Consent is not always required.
What the official source says
WRA’s technical guidance says it will use, share or disclose PTI where the law requires or permits this. It also says WRA will do so only after considering whether the particular purpose, recipient and scope make the step proportionate and in the public interest. That test still applies.
- WRA may use information for its own functions, subject to stated exceptions involving advice and assistance to Welsh Ministers and principal councils.
- It may share information if every person the information concerns has consented.
- It may share information to obtain services connected with a WRA function, including contracts and shared-service arrangements.
- It may disclose information for a criminal investigation, criminal proceedings, or preventing or detecting crime.
- It may disclose information to a professional regulator where this concerns misconduct by someone that regulator oversees.
- It may disclose information for civil proceedings or where a court or tribunal orders it.
- It may share information with someone carrying out WRA functions under a statutory delegation.
- It may disclose information where another law requires or permits it.
- It may share information with HMRC where that helps either body carry out its functions.
- It may share information with Revenue Scotland where that helps WRA, or helps Revenue Scotland collect and manage a Scottish devolved tax.
The list matters because it is purpose-led. The question is not simply who wants the information. It is why they need it and whether that reason fits a permitted route.
What this means in practice
Giving WRA information for an LTT return does not make it public, because the guidance limits use or sharing to routes that depend on the purpose and circumstances. It remains protected taxpayer information.
For example, WRA may use an outside provider to support a service connected with its work. The guidance says contracts and shared-service agreements can fall within the route for obtaining services.
That does not remove the need for care. A permitted route in the guidance is not a blank cheque to share additional information, with a wider recipient group or for a further use, than the stated purpose needs. Purpose sets the limit.
- Ask which information the proposed sharing covers, rather than assuming all records are needed.
- Check the exact purpose of the proposed sharing.
- Find out who will receive the information.
- Where someone suggests consent, check that every person concerned has given it.
- Keep a record of the reason given for the disclosure.
- Consider whether a court order, legal duty, or another specific legal power applies.
If somebody says WRA can share your information because it is “for tax purposes”, ask which permitted route applies, whose function it serves, and why the proposed disclosure is proportionate and in the public interest. You still need to identify the relevant permitted purpose.
How to analyse it
Start with the proposed use or disclosure. Then work through the reason for it before deciding whether the guidance points to a permitted route.
- What PTI does WRA propose to use or share?
- Is WRA using it itself, or giving it to another person or body?
- Which listed purpose is said to allow the step?
- Does the purpose concern WRA’s functions, services it needs, crime, proceedings, or another stated route?
- Has everyone the information relates to consented, if consent is the route relied on?
- Is there a court or tribunal order?
- Does another law require or permit the disclosure?
- Would the disclosure help HMRC or Revenue Scotland carry out the functions described in the guidance?
- Is the proposed step proportionate and in the public interest?
- Do separate privacy or data-protection restrictions limit what can be done?
Work in that order. A useful reason for sharing does not suffice on its own when it fails to match a permitted purpose, even if the recipient could use the information helpfully. The route must fit.
Example
Imagine that WRA needs a specialist supplier to run a service linked to checking LTT records. WRA may need to provide the supplier with information for that work. The guidance says obtaining services connected with a WRA function can permit sharing, including through a contract.
Now change the facts. Suppose the supplier wants to use the same records for its own unrelated research. The supplied guidance does not say that an unrelated purpose is allowed. The original service purpose would need to be kept separate from any new proposal.
No figures are needed here. What decides the point is the purpose of the sharing, not the value of the property or the amount of LTT involved.
Why this can be difficult in practice
Several categories in the guidance are broad. “For the purposes of WRA’s functions” and “where legislation permits” need to be tied to the real task that officials carry out.
Consent can also be less simple than it sounds. The guidance says each person the information relates to must give consent. One person’s agreement may therefore not settle the issue where information concerns more than one person.
There is a further safeguard. The guidance says other laws may prohibit or restrict use, sharing or disclosure. It gives data protection, human rights and GDPR as examples.
- Do not assume that consent is always needed; the guidance lists other routes.
- Do not assume that consent from one person covers everyone named in the information.
- Do not treat a supplier contract as permission for an unrelated use.
- Do not assume that a permitted disclosure avoids all other privacy rules.
- Do not overlook court or tribunal orders, which the guidance lists separately.
- Do not rely on the guidance’s older data-protection references without checking the current law.
The source also says officials who can access PTI must make a formal confidentiality declaration as soon as possible after appointment. WRA decides the form of that declaration.
Wrongful disclosure has serious consequences. According to the guidance, an official who unlawfully discloses PTI commits a criminal offence. It describes possible defences where the person reasonably believed disclosure was permitted, or where the information had already lawfully been made public. The person charged must prove the defence.
Key takeaways
- WRA guidance allows sharing of LTT taxpayer information only for defined purposes.
- The reason, recipient, scope and legal route all matter.
- Separate privacy restrictions may still limit a disclosure.
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
- The supplied guidance refers to the Data Protection Act 1998 and the EU GDPR. Those references may not reflect the current data-protection framework and need checking before reliance.
- The supplied statutory skill contains LTT legislation, but not the Tax Collection and Management (Wales) Act provisions governing this topic.
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 purpose for which the information is proposed to be shared
- Who would receive the information and what role they have
- Whether the person concerned has given valid consent
- Any court order, legal duty or statutory power relied on
- Why the disclosure is proportionate and in the public interest
- Any separate data-protection or human-rights restriction
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: When the Welsh Revenue Authority can share your tax information [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-taxpayer-information-technical-guidance#6654 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 refers to the Data Protection Act 1998 and the EU GDPR. Those references may not reflect the current data-protection framework and need checking before reliance. - The supplied statutory skill contains LTT legislation, but not the Tax Collection and Management (Wales) Act provisions governing this topic. 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: When the Welsh Revenue Authority can share your tax information
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