Land Transaction Tax: WRA taxpayer notices explained
Taxpayer notices and LTT
The WRA can use a taxpayer notice to ask you for information or documents you hold while checking Land Transaction Tax.
- Tribunal approval is usually optional.
- It is required for documents wholly more than six years old.
- Approval affects whether an appeal is available.
Scroll down for the full analysis.
Read the original guidance here:
Land Transaction Tax: WRA taxpayer notices explained
If the Welsh Revenue Authority (WRA) sends you a taxpayer notice about Land Transaction Tax (LTT), it is asking for information or documents that you hold. This can matter when the WRA checks a tax return. LTT replaced stamp duty land tax in Wales in 2018.
What this rule is about
As a formal request, a taxpayer notice lets the WRA obtain material from the person whose tax position it is checking, whether the request covers information, documents, or both. That is its purpose.
Whether a request seems unusual does not affect when this issue arises. Instead, the main question is whether the tribunal must approve it. This matters especially when the WRA asks for older documents.
What the official source says
Guidance from the WRA says that it may issue a taxpayer notice. When a notice asks its recipient to give information or produce a document in their possession, the guidance says that the WRA may impose that requirement. Usually, tribunal approval is not needed before the notice is sent.
- The notice can require information that you hold.
- It can require a document that you hold.
- Tribunal approval is required for a document wholly originating more than six years before the notice.
- Without tribunal approval, you may be able to appeal the notice or a particular requirement.
- With tribunal approval, you cannot appeal the decision to issue the notice or include that requirement.
What this means in practice
Read the notice closely. A request for information is not always a request for a document. Compare the WRA’s request with the material you have.
Do not assume that tribunal approval makes every question in the notice irrelevant. It changes your right to appeal. You still need to find the records the WRA has asked for.
- Keep the notice and any papers sent with it.
- List each item the WRA has requested.
- Check whether each document is wholly more than six years old.
How to analyse it
Start with the notice itself. Examine each item it asks for separately. This can help you avoid missing an old document. It can also stop you assuming that approval applies when it does not.
- Is this a taxpayer notice sent to you?
- Does it ask for information, a document, or both?
- Do you have the requested item in your possession?
- When did the whole requested document originate?
- Was tribunal approval obtained for the notice?
- Does the absence of approval leave an appeal open?
Example
For example, if a notice dated 10 June 2024 asks Nia for a document written wholly on 1 June 2018, tribunal approval is required because it is more than six years old. That document is more than six years old.
Under the official guidance, the WRA must get that approval before making the request. For a newer document, this six-year rule does not mean approval is needed.
Why this can be difficult in practice
The six-year point may sound simple. But a file may contain papers made at different times. A notice may also have more than one separate request.
You need to check whether the whole document is more than six years old. This is not always simple. For this purpose, the official source describes a document whose whole content began more than six years before the notice, even where a file contains material made at different times. That distinction matters.
- A file may include both old and newer material.
- A notice can have several separate requirements.
- The source does not explain appeal deadlines or the steps for making an appeal.
Key takeaways
- A taxpayer notice can ask for information or documents that you hold.
- Old documents may need tribunal approval before the WRA can request them.
- Tribunal approval can remove the right to appeal the notice requirement.
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 Schedule 4 para 1 — taxpayer notices requiring information or documents (provision not found on legislation.gov.uk)
- TCMA 2016 Schedule 4 para 3 — tribunal approval for information notices (provision not found on legislation.gov.uk)
- TCMA 2016 Schedule 4 para 20 — limits on requests for old documents (provision not found on legislation.gov.uk)
- TCMA 2016 Schedule 4 para 29 — appeals against information notice requirements (provision not found on legislation.gov.uk)
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 statutory skill materials do not include the Tax Collection and Management (Wales) Act 2016 or a currency notice. The current text and status of the cited Schedule 4 provisions should be checked before publication.
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.
- A copy of the taxpayer notice and every requirement in it.
- Details of any tribunal approval supplied with the notice.
- The date of the notice and the date each requested document was created.
- A record of which requested information and documents you hold.
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 Land Transaction Tax: WRA taxpayer notices explained [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 Schedule 4 para 1 - taxpayer notices requiring information or documents https://www.legislation.gov.uk/anaw/2016/6/schedule/4/paragraph/1 - TCMA 2016 Schedule 4 para 3 - tribunal approval for information notices https://www.legislation.gov.uk/anaw/2016/6/schedule/4/paragraph/3 - TCMA 2016 Schedule 4 para 20 - limits on requests for old documents https://www.legislation.gov.uk/anaw/2016/6/schedule/4/paragraph/20 - TCMA 2016 Schedule 4 para 29 - appeals against information notice requirements https://www.legislation.gov.uk/anaw/2016/6/schedule/4/paragraph/29 Guidance page from the Welsh Revenue Authority on this topic (guidance, not law): https://www.gov.wales/tax-collection-and-management-wales-act-2016-investigative-powers-technical-guidance#6683 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 statutory skill materials do not include the Tax Collection and Management (Wales) Act 2016 or a currency notice. The current text and status of the cited Schedule 4 provisions should be checked before publication. 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 4 September 2026
Useful article? You may find it helpful to read the original guidance here: Land Transaction Tax: WRA taxpayer notices explained
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