Land Transaction Tax: third-party information notices
Third-party notices for Land Transaction Tax
The WRA may ask another person for information or documents to check an LTT position. Its guidance says the notice normally needs tribunal approval or the taxpayer’s agreement, and the taxpayer should normally be named and sent a copy.
- Special rules apply to company groups.
- Special rules also apply to partnerships.
- The tribunal may remove some requirements where serious prejudice is likely.
Scroll down for the full analysis.
Read the original guidance here:
Land Transaction Tax: third-party information notices
The Welsh Revenue Authority (WRA) can ask someone else for information about your Land Transaction Tax (LTT) position. LTT replaced Stamp Duty Land Tax in Wales in 2018.
A bank, business, agent or another person may hold relevant records. Record holders may receive a third-party notice. Safeguards limit when the WRA can issue one.
What this rule is about
Most people expect the WRA to ask them first. Sometimes it needs information held by somebody else instead. Official guidance calls this a third-party notice.
WRA checks another person’s tax position here. It may require its recipient to provide information or produce a document. The records can verify the LTT paid.
An important safeguard applies: the WRA needs either tribunal approval or the agreement of the person whose tax position it is checking. That distinction matters.
What the official source says
WRA guidance says a third-party notice must identify the person whose tax position the WRA is checking. It must also send that person a copy of the notice. This gives them a chance to know what information the WRA has requested about them.
- A notice can require a third party to provide information about another person.
- It can also require the third party to produce a document.
- Unless the taxpayer agrees, the tribunal must approve the notice.
- Normally, the notice must name the taxpayer.
- The taxpayer must normally receive a copy of the notice.
- Serious prejudice may remove either requirement. The tribunal decides.
Extra rules apply where the notice concerns a group of undertakings or a partnership. They make clear whose tax position the WRA is checking.
- For a group, the notice must state that it is checking the tax position of a parent undertaking or one of its subsidiaries.
- For this purpose, the parent undertaking counts as the taxpayer for agreement and copy requirements.
- For a partnership, a notice sent to a non-partner must state its purpose.
- It must give the partnership’s registered name, or the name by which it is known.
- The WRA must normally send a copy of that notice to at least one partner.
- Serious prejudice may disapply these requirements. The tribunal decides.
What this means in practice
If you receive a notice, it may concern somebody else’s LTT affairs rather than your own tax position. Start by reading whom the notice identifies and what it asks you to provide.
As the person named in the notice, you would normally receive a copy. A missing copy does not always mean the notice is invalid.
In limited circumstances, the tribunal may have allowed the WRA not to name you or not to send you a copy.
- Keep the full notice, including attachments and covering letters.
- Check whether it identifies the person the WRA is checking.
- For a group, check whether it identifies the parent undertaking and states its purpose.
- For a partnership, check whether it gives the partnership name and whether a partner received a copy.
How to analyse it
First ask: is this a notice about your own LTT position, or does it seek material about somebody else? The answer changes which safeguards should be visible on the paperwork.
Then work through the notice in order. Do not assume that a group company and its parent are interchangeable. The guidance gives the parent undertaking a specific role for these notice rules.
- Identify the recipient of the notice.
- Identify the person or business whose tax position the WRA is checking.
- Check whether the notice asks for information, documents, or both.
- Ask whether the tribunal approved it or the taxpayer agreed.
- Check the special wording if a group of undertakings is involved.
- Check the special name and copy requirements if a partnership is involved.
Example
When the WRA checks LTT connected with Green Street Holdings Ltd and asks its records provider for documents, the notice must state its purpose if it concerns the parent undertaking or a subsidiary. For the agreement and copy rules, the parent undertaking is treated as the taxpayer.
Change the facts. If the WRA asks a non-partner for records about the Riverside Partnership, the notice must state its purpose and give the partnership’s registered or known name.
At least one partner should normally receive a copy. The tribunal can direct otherwise only where the serious-prejudice test is met.
Why this can be difficult in practice
Several people may be involved, which can make the paperwork confusing: the recipient, the person under review, a parent company, a subsidiary, or a partner. Names matter. A notice about a partnership has different added requirements from one about a company group.
You might think every person under review must always get a copy. That is the normal position described by the guidance, but it is not absolute.
Where giving the name or copy might seriously harm the assessment or collection of tax, the tribunal can remove the usual protections.
- A third party may mistake another person’s notice for its own tax enquiry.
- A company group may focus on a subsidiary when the parent has the formal role.
- A partnership may be known by a trading name rather than its registered name.
- The supplied guidance does not explain every response step or consequence of non-compliance.
Key takeaways
- The WRA can seek relevant information from another person about LTT.
- Tribunal approval or the taxpayer’s agreement is normally needed.
- Groups and partnerships have extra notice and copy requirements.
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 materials do not include the current text of the Tax Collection and Management (Wales) Act 2016 provisions behind this guidance.
- The current status of the underlying statutory rules could not be checked against a currency notice in the mounted skills.
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 complete third-party notice
- any copy sent to the person whose tax position is checked
- any written agreement to the notice
- any tribunal approval or tribunal direction
- group or partnership records relevant to the notice
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: third-party information notices [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-investigative-powers-technical-guidance#6685 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 materials do not include the current text of the Tax Collection and Management (Wales) Act 2016 provisions behind this guidance. - The current status of the underlying statutory rules could not be checked against a currency notice in the mounted skills. 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: third-party information notices
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