LTT group relief: who can be chased for unpaid tax?
When can WRA recover unpaid LTT?
If group relief is withdrawn and the buyer company does not pay the final tax bill within six months, WRA may issue recovery notices to other specified people.
- The buyer company remains responsible first.
- The statute can also reach the seller, certain parent-group companies and controlling directors.
- A recovery notice normally requires payment within 30 days.
Scroll down for the full analysis.
Read the original guidance here:
LTT group relief: who can be chased for unpaid tax?
If group relief is later withdrawn, the buyer company must pay the extra Land Transaction Tax (LTT), Wales’s form of stamp duty. When it does not pay and the legal conditions are met, WRA may in some cases seek the unpaid amount from other people or companies. The reach may widen.
What this rule is about
Group relief can remove LTT. It applies when land moves between companies in the same group. That saving is not always permanent. A later change can cause the relief to be withdrawn and create a tax bill.
Responsibility starts with the buyer company. This recovery rule matters when that company has not paid after the bill has become final.
What the official source says
According to WRA’s technical guidance, recovery from others becomes possible when tax resulting from a withdrawal is settled, remains unpaid, and has been overdue for six months after its payment date. Only then can recovery extend further.
Possible targets identified in the guidance include companies above the buyer and controlling directors.
- Group relief must have been withdrawn to create the tax.
- Final determination of the amount due is required.
- All or part of it must still be unpaid six months after its payment date.
- A parent-group company may be within the rule.
- A controlling director may also be within the rule.
- WRA must serve a notice on the person or company it wants to pay.
One important point needs adding. Statute also names the seller as a person who may receive a recovery notice. The supplied official source does not include the seller in its list.
What this means in practice
This rule is not automatic. WRA must first meet the legal conditions and issue a notice. Yet the risk can reach beyond the company that bought the land.
- A company higher up the group may be exposed if, at the relevant time and within the applicable group structure, it was above the buyer when the withdrawal conditions arose. Its current position may differ.
- The relevant period runs from the LTT transaction date to the event that caused the withdrawal.
- A director must have had control of the buyer, or of a company controlling it.
- The notice must state the amount WRA says remains unpaid.
- The person sent the notice normally has 30 days from its issue date to pay.
- Someone who pays under a notice may recover that amount from the buyer company.
That distinction can matter greatly. Directorship alone is insufficient. The person must be a controlling director under the statutory control rules.
How to analyse it
Begin with the unpaid bill, rather than the current company chart. Ask who held the right position during the period set by the law.
- Check that the original land transfer received group relief.
- Identify why and when the relief was withdrawn.
- Confirm the amount due has become final and cannot be changed by review or appeal.
- Check whether six months have passed without full payment.
- Map the group from the transaction date to the withdrawal event.
- Identify any company above the buyer through the 75% subsidiary chain.
- Check who controlled the buyer or its controlling company during that period.
- Read the notice carefully, including its date and the sum claimed.
Example
Imagine a group company that buys land from another group company, claims group relief, later has that relief withdrawn, and does not pay the final LTT bill within six months. The bill remains unpaid.
WRA may then issue a notice to a qualifying company above the buyer in the group. It may also issue one to a person who was a controlling director during the relevant period. That notice sets out the unpaid sum and gives 30 days for payment.
Why this can be difficult in practice
Group structures can change quickly. A current organisation chart may not show who was above the buyer when it matters. Share rights, profit rights and winding-up rights can all affect the 75% test.
- People often look only at the group structure when the notice arrives.
- A company may have been above the buyer earlier, even if it is not now.
- A job title does not settle whether someone counts as a director.
- Control can be held through rights and arrangements, not just a simple share majority.
- The source page omits the seller, although the statute includes it.
- The six-month period starts when the tax became payable, not simply when the original transfer happened.
If you only remember one thing, make it this: the buyer company is first in line, but unpaid LTT after withdrawn group relief can reach further.
Key takeaways
- Withdrawn group relief can create an LTT bill.
- WRA can recover unpaid tax from specified others after six months.
- The seller, qualifying parent companies and controlling directors may be within scope.
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 2 — when companies can claim group relief
- LTTA 2017 Schedule 16 para 8 — when group relief can be withdrawn
- LTTA 2017 Schedule 16 para 13 — who may be required to pay unpaid tax
- LTTA 2017 Schedule 16 para 14 — notices for recovery of unpaid group relief tax
- an Act of 2003 we do not have an identifier for section 67 — meaning of director for this recovery rule (no link: an Act of 2003 we do not have an identifier for)
- an Act of 2010 we do not have an identifier for section 450 — general meaning of company control (no link: an Act of 2010 we do not have an identifier for)
- an Act of 2010 we do not have an identifier for section 451 — how control of a company is worked out (no link: an Act of 2010 we do not have an identifier for)
- an Act of 2010 we do not have an identifier for section 452 — people included within the director definition (no link: an Act of 2010 we do not have an identifier for)
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 page lists parent-group companies and controlling directors, but LTTA 2017 Schedule 16 paragraph 13 also permits recovery from the seller.
- The supplied skill materials contain no currency notice recording the date to which the statute is current. Current wording should be checked before relying on this page for a later transaction or notice.
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 of the original group-relieved transaction
- The date and reason group relief was withdrawn
- The final determination of the tax due
- Evidence of payment or any unpaid balance
- The group structure during the relevant period
- Shareholdings, voting rights and control arrangements
- Directorship records for the buyer and its controlling companies
- Any recovery notice issued by WRA
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: who can be chased for unpaid 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 16 para 2 - when companies can claim group relief https://www.legislation.gov.uk/anaw/2017/1/schedule/16/paragraph/2 - LTTA 2017 Schedule 16 para 8 - when group relief can be withdrawn https://www.legislation.gov.uk/anaw/2017/1/schedule/16/paragraph/8 - LTTA 2017 Schedule 16 para 13 - who may be required to pay unpaid tax https://www.legislation.gov.uk/anaw/2017/1/schedule/16/paragraph/13 - LTTA 2017 Schedule 16 para 14 - notices for recovery of unpaid group relief tax https://www.legislation.gov.uk/anaw/2017/1/schedule/16/paragraph/14 - an Act of 2003 we do not have an identifier for section 67 - meaning of director for this recovery rule - an Act of 2010 we do not have an identifier for section 450 - general meaning of company control - an Act of 2010 we do not have an identifier for section 451 - how control of a company is worked out - an Act of 2010 we do not have an identifier for section 452 - people included within the director definition Guidance page from the Welsh Revenue Authority on this topic (guidance, not law): https://www.gov.wales/land-transaction-tax-group-relief-technical-guidance#6209 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 page lists parent-group companies and controlling directors, but LTTA 2017 Schedule 16 paragraph 13 also permits recovery from the seller. - The supplied skill materials contain no currency notice recording the date to which the statute is current. Current wording should be checked before relying on this page for a later transaction or notice. 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: who can be chased for unpaid tax?
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