Land Transaction Tax (LTT): the 30-day time limit for appeals
LTT appeal deadlines
You normally have 30 days to appeal an appealable WRA decision to the tribunal. The date that starts the period depends on whether there was a review, a withdrawn settlement, or an enquiry.
- Check which event starts your 30-day period.
- Keep all WRA notices and correspondence.
- A late appeal needs the tribunal’s permission.
Scroll down for the full analysis.
Read the original guidance here:
Land Transaction Tax (LTT): the 30-day time limit for appeals
Land Transaction Tax (LTT): the 30-day time limit for appeals
If you want to challenge a Land Transaction Tax decision, time matters. You normally have 30 days to send a notice of appeal to the tribunal. The key question is: which date starts those 30 days?
What this rule is about
The Welsh Revenue Authority, known as the WRA, can make LTT decisions. Some are appealable decisions. The law therefore lets you ask the tribunal to decide whether the WRA’s decision should stand.
You may have asked the WRA to review its decision first. You may also have reached a settlement and later left it. Each route can give a different starting date for an appeal.
That detail can decide whether your appeal is on time.
What the official source says
The WRA’s technical guidance says that an appeal must be made by giving a notice of appeal to the tribunal within 30 days. The date that starts the period depends on what happened before the appeal.
- If you did not request a review, the 30-day period runs from the date on which the WRA notified you of its decision, which is the relevant starting event. That date controls.
- If you asked for a review, the period runs from the date when the WRA notified you of its review conclusions, because those conclusions provide the relevant event before an appeal. That date controls.
- If you entered a settlement agreement but then withdrew, time runs from the withdrawal date.
- If the WRA amended your tax return during an enquiry, the period runs from notice that the enquiry ended, because that notice identifies the relevant starting event for an appeal. That date controls.
- If the appeal is late, you may still ask the tribunal for permission to make it.
- The tribunal will tell you whether it gives that permission.
What this means in practice
The first letter may not control. If you asked for a review, the later review notice may be the important document instead.
Keep every letter, email and online message from the WRA. You need to be able to show what was sent, when it was sent and which stage of the process it relates to.
- Find the decision you want to challenge.
- Check whether you requested a review.
- Find the WRA’s review conclusions, if there was a review.
- Check whether a settlement was made and then withdrawn.
- For an enquiry, find the notice saying it was completed.
- Send the notice of appeal to the tribunal within the relevant 30-day period.
How to analyse it
Start with the decision, then work forwards. The point is not simply when you first spoke to the WRA. It is which of the four events in the official guidance applies to your case.
- Is the WRA decision one that can be appealed?
- Did you ask the WRA for a review before appealing?
- Did the WRA send its conclusions from that review?
- Did you withdraw from a settlement agreement?
- Was the decision an amendment made while an enquiry was still open?
- If so, when did the WRA notify you that the enquiry had ended?
- Can you prove the relevant date from your records?
Example
Illustration: Amina receives an LTT decision from the WRA. She asks for a review. The WRA later sends its review conclusions. For her appeal, the official guidance says the 30-day period runs from the date the WRA notified her of those conclusions, not from the earlier decision notice.
If Amina sends her appeal after that period, it does not automatically mean the tribunal will hear it. She needs the tribunal’s permission for a late appeal.
Why this can be difficult in practice
People often focus on the first letter from the WRA. That can be the wrong date. A review, a withdrawn settlement, or the end of an enquiry may change the starting point.
The source does not explain how the tribunal decides late-appeal requests. It also does not give detailed rules for disputes about when a notice was received. Those points may matter where the deadline is close.
- A review request can change the date that matters.
- A settlement agreement can affect the appeal route if you later withdraw.
- An enquiry-related amendment has its own starting event.
- Missing or unclear WRA correspondence can make the deadline hard to prove.
- Permission for a late appeal is not automatic.
Key takeaways
- An LTT appeal normally has a 30-day time limit.
- The correct starting date depends on your route to appeal.
- Keep the WRA notices that show the relevant date.
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 179 — time limit for making an appeal
- TCMA 2016 section 180 — tribunal permission for a late appeal
- TCMA 2016 section 181 — how the tribunal decides an appeal
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 material does not set out the tribunal’s test for allowing a late appeal.
- The current statutory text should be checked before relying on a deadline in a live case.
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 WRA decision notice and the date it was issued
- Any request for review and the WRA’s review conclusions
- Any settlement agreement and evidence of withdrawal
- Any notice confirming that an enquiry has ended
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 (LTT): the 30-day time limit for appeals [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 179 - time limit for making an appeal https://www.legislation.gov.uk/anaw/2016/6/section/179 - TCMA 2016 section 180 - tribunal permission for a late appeal https://www.legislation.gov.uk/anaw/2016/6/section/180 - TCMA 2016 section 181 - how the tribunal decides an appeal https://www.legislation.gov.uk/anaw/2016/6/section/181 Guidance page from the Welsh Revenue Authority on this topic (guidance, not law): https://www.gov.wales/tax-collection-and-management-wales-act-2016-reviews-and-appeals-technical-guidance#6636 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 material does not set out the tribunal's test for allowing a late appeal. - The current statutory text should be checked before relying on a deadline in a live case. 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 (LTT): the 30-day time limit for appeals
Search Land Tax Advice with Google
