Guidance on SDLT Returns for Linked Land Transactions in Wales and England

Later linked transactions for Welsh land before 1 April 2018

If a Welsh land transaction took effect before 1 April 2018, it stays within SDLT, even if a later linked transaction happens after Land Transaction Tax started. Where the later linked SDLT transaction makes the earlier Welsh transaction notifiable, or increases the tax due, an SDLT filing may still be required under the special rules.

• A Welsh land transaction with an effective date before 1 April 2018 does not move into LTT just because a later linked transaction happens after that date.
• If the earlier transaction was below the SDLT notification threshold when considered on its own, it may later become notifiable because of a linked SDLT transaction.
• In that case, the earlier transaction remains subject to SDLT and a return may need to be made under section 81A of Finance Act 2003.
• If the earlier transaction was not previously notified, the return is made on paper using form SDLT1 and sent to Birmingham Stamp Taxes with a covering letter.
• If the earlier transaction was already notified but the later linked transaction means more tax is due, the further return is made by letter to Birmingham Stamp Taxes.
• The key practical checks are the effective date, whether the transactions are linked for SDLT purposes, and whether the linkage changes the filing or tax position.

Scroll down for the full analysis.

Later linked transactions involving Welsh land before 1 April 2018

This page explains what happens where a land transaction in Wales took place before 1 April 2018, was not notifiable for SDLT at the time, but later becomes notifiable because it is linked to a later SDLT transaction. The point matters because the earlier Welsh transaction does not move into LTT just because the later transaction happens after LTT began. In the circumstances described by the official material, the earlier transaction remains within SDLT and an SDLT return may have to be filed later.

What this rule is about

Before 1 April 2018, transactions involving Welsh land could fall within SDLT. From 1 April 2018, LTT replaced SDLT for Welsh land transactions. That change can create difficulties where there is more than one transaction and the transactions are linked.

The specific issue here is an earlier Welsh transaction that was below the SDLT notification threshold, so no SDLT return was needed at the time. If a later SDLT transaction is linked to it, the combined position may make the earlier transaction notifiable. Section 81A of Finance Act 2003 deals with that situation.

The key point is that the earlier Welsh transaction keeps its SDLT character if its effective date was before 1 April 2018. It does not become an LTT transaction simply because the later linked transaction happens after LTT came into force.

What the official source says

The official material says that where:

• a land transaction relating to land in Wales has an effective date before 1 April 2018,
• that transaction was not notifiable for SDLT purposes at that time, and
• it becomes notifiable on or after 1 April 2018 because of a later SDLT transaction that is linked to it,

the earlier transaction remains subject to SDLT. A return must then be submitted under section 81A FA 2003.

The source also covers the related case where the earlier transaction was already notified. If tax, or additional tax, becomes due because of the later linked transaction, a further return must still be made, but the official process is by letter to Birmingham Stamp Taxes.

What this means in practice

You need to look at the timing and at whether the transactions are linked for SDLT purposes.

If the earlier Welsh transaction took effect before 1 April 2018, it stays in the SDLT regime. That remains true even if the later linked transaction happens on or after 1 April 2018.

If the earlier transaction was below the notification threshold when looked at on its own, no return may have been needed then. But once there is a later linked SDLT transaction, the earlier transaction may become notifiable. In that case, an SDLT return must be filed for the earlier transaction under section 81A.

The official material also gives procedural instructions. Where the earlier transaction had not previously been notified, the return must be made on paper using form SDLT1 and sent to Birmingham Stamp Taxes with a covering letter. The effective date entered in Box 4 should be the effective date of the later linked transaction. The return should use special local authority code 6998, not a Welsh local authority code.

Where the earlier transaction had already been notified, but the later linked transaction means that tax or more tax is due, the further return is made by letter to Birmingham Stamp Taxes in line with the manual instructions referred to in the source.

How to analyse it

A sensible way to approach this issue is to ask the following questions:

• Was there an earlier transaction relating to land in Wales?
• What was the effective date of that earlier transaction? If it was before 1 April 2018, that points towards SDLT rather than LTT.
• Was that earlier transaction not notifiable when viewed on its own?
• Is there a later transaction that is still an SDLT transaction?
• Are the two transactions linked for SDLT purposes?
• Does the later linked transaction make the earlier one notifiable, or increase the SDLT due?
• Was the earlier transaction ever notified already? If not, a paper SDLT1 is required. If it was, the official material says the further return is made by letter.

The practical focus is not only on whether there is a later transaction, but on whether it is linked and whether that linkage changes the SDLT filing or tax position for the earlier Welsh transaction.

Example

Illustration based on the official example: a buyer acquires a field in Wales before 1 April 2018 for £35,000. On its own, that amount is below the SDLT notification threshold, so no SDLT return is required at that stage. The buyer later completes a linked purchase of a field wholly in England on 1 April 2018 for £250,000.

According to the official material, the two transactions remain linked for SDLT purposes because the Welsh transaction took place before LTT came into force. The earlier Welsh transaction therefore remains within SDLT. A further return is required for that earlier transaction under section 81A FA 2003.

Why this can be difficult in practice

The main difficulty is that the transaction involving Welsh land happened before the switch from SDLT to LTT, but the linked transaction happened after that switch. That can make it tempting to assume that the Welsh element should now be dealt with under LTT. The official material says that is not the correct approach in this situation.

Another practical difficulty is procedural. The source does not describe an ordinary online filing route. Instead, it requires a paper SDLT1 with specific entries, or a letter where the earlier transaction was already notified. If that is missed, the filing position may not be regularised correctly.

A further area requiring care is the linked transaction analysis itself. This page assumes that the transactions are linked. Whether transactions are linked can be fact-sensitive, and that question must be answered under the SDLT rules.

Key takeaways

• An earlier Welsh land transaction with an effective date before 1 April 2018 remains within SDLT if it later becomes notifiable because of a linked later SDLT transaction.
• The start of LTT does not, by itself, move that earlier transaction out of SDLT.
• If the earlier transaction was not previously notified, the official process is a paper SDLT1 to Birmingham Stamp Taxes with the later transaction’s effective date in Box 4 and special code 6998.

This page was last updated on 24 March 2026

Useful article? You may find it helpful to read the original guidance here: Guidance on SDLT Returns for Linked Land Transactions in Wales and England

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