Land Transaction Tax: WRA can share personal tax information only where the law permits
WRA taxpayer information
WRA can use tax information for its functions, but people covered by the law must normally keep identifiable taxpayer information confidential.
- PTI is information that could identify a person.
- The duty can cover staff, former staff and service providers.
- A legal permission is needed before PTI can be disclosed.
Scroll down for the full analysis.
Read the original guidance here:
Land Transaction Tax: WRA can share personal tax information only where the law permits
Land Transaction Tax: WRA can share personal tax information only where the law permits
The Welsh Revenue Authority (WRA) holds personal tax information when it deals with Land Transaction Tax. It cannot use that information however it likes. In law, limits apply to its use, and people working for WRA must normally keep it private.
What this rule is about
Tax information can reveal a lot about someone. It can show a property purchase, a name, an address, or details given to WRA during a tax check.
This legal rule draws a line around the information: it lets WRA use it to do its job while protecting people from casual or improper sharing. That protection matters.
This matters because confidentiality is not just good practice. It is a legal duty for the people covered by the rule.
What the official source says
WRA may use information it gets while carrying out its functions only in connection with those functions, although any UK international obligation that restricts or prevents use of the information overrides that permission. That constraint applies.
Official guidance calls certain material protected taxpayer information, or PTI. In simple terms, this is information held by WRA that could identify a person.
- PTI includes information held by WRA itself.
- It can also include information held by someone carrying out work delegated by WRA.
- Information about WRA’s own internal administration is not PTI under this definition.
- Information about a WRA staff member is also outside this definition.
- A relevant official must keep PTI confidential.
- The general position is that a relevant official must not disclose PTI.
- Disclosure can happen where a law specifically permits it.
What this means in practice
If you give WRA information for a Land Transaction Tax matter, it is not free for general use. WRA can use it for its work. That is the key limit.
You might think the rule reaches only permanent WRA staff. That is too narrow. This duty also reaches people who provide services or carry out functions for WRA.
- Current WRA staff are relevant officials.
- Former WRA staff are also covered.
- Members of WRA committees and sub-committees are covered.
- People doing work or providing services for WRA can be covered.
- The rule can reach people providing services to someone acting under delegated WRA functions.
PTI exclusion grants no general publication rights. It simply means that this particular confidentiality definition does not apply to that material.
How to analyse it
Where someone questions whether information may be used or shared, start with the facts about the information, who holds it, and what they plan to do with it. Begin there.
A document’s label will not decide the issue on its own.
Ask one question at a time: what is the information, who has it, and what are they planning to do with it?
- Was the information obtained by WRA while doing its functions?
- Could the information lead to a person being identified?
- Does it concern WRA’s internal administration or a WRA staff member?
- Is the person using or sharing it a relevant official?
- Is the proposed use connected with WRA’s functions?
- Is there an international obligation that limits use?
- What legal provision, if any, permits the proposed disclosure?
Often, the last question matters most. A wish to share information is not enough. There must be a legal basis where the information is PTI.
Example
Imagine that Mari sends WRA details about her Land Transaction Tax return. The details could identify her, so they are likely to be PTI. A WRA worker may use them to deal with the return or related WRA work. That worker cannot simply pass them to another person because they think it would be useful. The source says disclosure needs a specific legal permission.
Why this can be difficult in practice
Often, the difficult part is not the basic rule but deciding whether information could identify someone and whether a particular legal permission allows sharing in the circumstances that have arisen. That requires care.
Information does not need to state a person’s name to raise this issue. Instead, ask whether it could lead to that person being identified.
- A document may contain both PTI and material outside the definition.
- A contractor may be a relevant official even though they are not WRA staff.
- Former staff remain within the group described by the source.
- The source does not set out every legal exception to the ban on disclosure.
- International obligations may place an added limit on use.
If you only remember one point, make it this: WRA tax information is protected by a legal duty of confidence, not merely an informal promise.
Key takeaways
- WRA can use information it obtains for its functions.
- Information that could identify a person may be PTI.
- Relevant officials must not disclose PTI unless the law permits it.
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 17 — how WRA may use information it obtains
- TCMA 2016 section 18 — confidentiality rules for protected taxpayer information
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 a particular disclosure is allowed depends on the specific legal power or duty said to permit it.
- The supplied official guidance does not explain how the law applies to every type of information request.
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.
- What information is involved and how it could identify a person.
- Who holds, receives or plans to share the information.
- The legal provision said to allow any proposed disclosure.
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 How WRA can use your tax information and keep it confidential [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 17 - how WRA may use information it obtains https://www.legislation.gov.uk/anaw/2016/6/section/17 - TCMA 2016 section 18 - confidentiality rules for protected taxpayer information https://www.legislation.gov.uk/anaw/2016/6/section/18 Guidance page from the Welsh Revenue Authority on this topic (guidance, not law): https://www.gov.wales/tax-collection-and-management-wales-act-2016-taxpayer-information-technical-guidance#6650 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 a particular disclosure is allowed depends on the specific legal power or duty said to permit it. - The supplied official guidance does not explain how the law applies to every type of information request. 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 can share personal tax information only where the law permits
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