What counts as an arrangement for LTT anti-avoidance rules
Arrangement meaning for LTT
The Welsh anti-avoidance rule uses a wide meaning of “arrangement”. It can cover formal and informal steps, as well as a series of linked actions.
- It is not limited to signed contracts.
- Linked steps may be considered together.
- Being an arrangement does not alone prove tax avoidance.
Scroll down for the full analysis.
Read the original guidance here:
What counts as an arrangement for LTT anti-avoidance rules
For Land Transaction Tax (LTT), the Welsh anti-avoidance rule can look at far more than a signed contract.
The rule may treat a promise, an action or a linked set of events as an arrangement. That matters when people planned steps to produce a tax saving.
What this rule is about
The general anti-avoidance rule applies across Welsh devolved taxes, including LTT. Its aim is to deal with artificial tax avoidance.
Before that wider rule can apply, there must first be an arrangement.
The word has a broad meaning on purpose. People cannot keep a step outside the rule merely because they left it informal, unfinished or not legally binding while pursuing a wider plan. The label does not decide.
What the official source says
The official technical guidance explains that the law can include many different things within an arrangement.
One item may stand alone, a series may unfold, or items may operate together in a connected combination. The guidance is not the law, but it reflects the wording in the Act.
- Transactions can be arrangements.
- Schemes can be arrangements.
- Actions or operations can be arrangements.
- Agreements or grants can be arrangements.
- Understandings can be arrangements.
- Promises or undertakings can be arrangements.
- Events can be arrangements.
- Series of transactions can be arrangements.
- Mixtures of linked steps can be arrangements.
What this means in practice
When assessing a property purchase, look at the whole plan and every linked step around it, rather than only at the document used to buy the property.
A buyer may take several linked steps. The rule can treat those steps together where they form a series.
This point alone does not mean anyone has avoided tax. The law also asks whether obtaining a tax advantage was a main purpose when a person entered into the arrangement, alongside any other purpose they had at the time.
That purpose matters.
- Keep records that explain the real reason for each step.
- Do not assume an oral understanding does not matter.
- Check linked actions before and after the property purchase.
- Consider events that happened as part of the wider plan.
How to analyse it
Start with what actually happened. Then place the events in order and ask whether they connect. Labels are less important than the substance of the steps.
- List every agreement, action, promise and event.
- Put the steps into a clear timeline.
- Identify which people took part in each step.
- Ask whether the steps were planned as one course of action.
- Work out whether a tax saving was a main purpose.
Example
Rhodri agrees to buy land, makes an informal promise to another person, and later carries out a linked transfer as part of the same course of events.
There is no single document covering every step. Even so, the relevant people could consider the promise, purchase and later transfer together as an arrangement.
Whether the wider anti-avoidance rule applies would need more than that fact alone.
Why this can be difficult in practice
This is the part people can miss: an arrangement need not look like a formal scheme. Ordinary events may be linked by a shared plan. The answer will often turn on documents, timing and the reasons for each step.
- The question does not end with a missing contract.
- One step may be part of a larger series.
- Separate people may still be involved in connected steps.
- Tax saving alone does not settle the wider test.
Key takeaways
- For LTT anti-avoidance rules, an arrangement has a very wide meaning.
- Informal promises and events can count, not only contracts.
- The full facts matter when deciding whether linked steps form one arrangement.
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 81B — when an arrangement is tax avoidance; the wide meaning of an arrangement
- LTTA 2017 section 66 — inserts the Welsh general anti-avoidance rule
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 connected events form one arrangement will depend on the facts, including their purpose and links.
- This source does not give a full test for deciding whether an arrangement is artificial.
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.
- contracts, emails and written agreements
- a timeline of each step and event
- records explaining why each step was taken
- details of any tax result expected from the steps
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 What counts as an arrangement for LTT anti-avoidance rules [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 81B - when an arrangement is tax avoidance https://www.legislation.gov.uk/anaw/2016/6/section/81B - TCMA 2016 section 81B - the wide meaning of an arrangement https://www.legislation.gov.uk/anaw/2016/6/section/81B - LTTA 2017 section 66 - inserts the Welsh general anti-avoidance rule https://www.legislation.gov.uk/anaw/2017/1/section/66 Guidance page from the Welsh Revenue Authority on this topic (guidance, not law): https://www.gov.wales/tax-collection-and-management-wales-act-2016-general-anti-avoidance-rule-technical-guidance#6583 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 connected events form one arrangement will depend on the facts, including their purpose and links. - This source does not give a full test for deciding whether an arrangement is artificial. 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: What counts as an arrangement for LTT anti-avoidance rules
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