Removing an LTT charge after an alternative finance bond ends
Removing the LTT charge
After land returns to its original owner at the end of an alternative finance investment bond, the bond issuer can provide evidence to WRA so that the registered LTT charge ceases.
- The required conditions include the bond arrangements, capital payments and return-transfer time limits.
- The issuer needs a confirming statement, two LTT return reference numbers and registration evidence.
- WRA must notify the Chief Land Registrar within 30 days of receiving the evidence.
Scroll down for the full analysis.
Read the original guidance here:
Removing an LTT charge after an alternative finance bond ends
Removing an LTT charge after an alternative finance bond ends
A charge on the land can be removed when an alternative finance investment bond has ended properly and the bond issuer gives Welsh Revenue Authority, or WRA, the right evidence. This is not a new stamp duty bill. Instead, it clears the registered LTT security from the land.
What this rule is about
These rules apply to a particular type of alternative finance arrangement. Under it, the original owner transfers land to a bond issuer. It holds land as a bond asset. When the bond ends, it transfers land back.
At the start, a legal charge is registered against the land. It protects WRA if the arrangement later fails to meet the conditions for LTT relief. Potential tax on the first transfer, along with possible interest and penalties, can be covered by the charge.
That can sound alarming. It does not mean the land has been taken away or that tax is automatically due.
Once the land has returned and the required conditions are met, the bond issuer can provide evidence so the charge no longer affects the land.
What the official source says
After the effective date of the second transfer, the law says the land stops being subject to the charge. WRA must receive the prescribed evidence from the bond issuer showing that conditions 1 to 3 and 5 to 7 have been met.
Official technical guidance describes that evidence. It concerns the process; the statutory rule itself is in Schedule 11 to the Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017.
- The original owner and bond issuer must have agreed both the first transfer and the later transfer back.
- It must have entered the investment bond. Land must have been its bond asset.
- The arrangement must include a leaseback, or meet another prescribed income condition.
- Capital paid to the issuer before the bond ends must be at least 60% of the land’s market value at the first transfer.
- The issuer must hold the land as a bond asset until the bond ends.
- The land must return to the original owner within 30 days after it stops being a bond asset.
- Ten years is the limit. A prescribed period may replace it.
For the evidence package, the guidance says WRA needs more than a general request to remove the charge.
- A statement from the bond issuer, or its authorised representative, must confirm that conditions 1 to 3 and 5 to 7 have been met.
- Support it with first-transfer LTT return UTRN.
- It must also include the UTRN for the LTT return on the transfer back to the original owner.
- Chief Land Registrar document confirms original-owner registration.
What this means in practice
Evidence goes to WRA from the bond issuer, not the original owner. Once the statutory requirements are met and that evidence has been supplied, the land ceases to be subject to the registered charge.
WRA must then notify the Chief Land Registrar. Starting with the date the issuer provides the evidence, the law gives WRA 30 days to send that notice under the land registration rules.
There are therefore two connected stages: proving that the arrangement ended in the required way, then updating the register.
- Keep the two LTT return reference numbers with the transaction papers.
- Make sure the land registration shows the original owner as the registered owner.
- Check that the issuer’s statement covers every required condition, not only the transfer back.
- Record the date on which WRA received the evidence, as it starts WRA’s 30-day notification period.
How to analyse it
Start with the sequence of events rather than the paperwork. A correct-looking statement cannot cure an arrangement that missed one of the legal conditions.
- Was there a first transfer from the original owner to the bond issuer?
- Did the parties agree from the start that the land would return to that owner?
- Was the land held as a bond asset under the relevant investment bond?
- Did the income arrangements meet the leaseback or other permitted condition?
- Did capital payments reach the required 60% level before the bond ended?
- Was the land held until the bond ended, rather than returned early?
- Did the return transfer meet both the 30-day and 10-year timing rules?
- After that transfer, can the issuer give each item in the prescribed evidence package?
Example
Imagine a bond issuer holding land as a bond asset when the bond ends. Within 30 days, the issuer transfers the land back to its original owner. The second transfer takes effect within 10 years of the first one. Required capital arrangements have been made, and the issuer has both LTT return reference numbers.
After the return transfer takes effect, the issuer sends WRA its signed statement, the two UTRNs, and the Land Registry document showing the original owner registered again. Where conditions 1 to 3 and 5 to 7 are met, the land stops being subject to the charge. Within 30 days of receiving that evidence, WRA must notify the Chief Land Registrar.
Why this can be difficult in practice
A transfer back is not the whole test. This is the part people can miss. Only where the wider conditions are met and the issuer provides the specified evidence after the second transfer takes effect is the charge removed.
Timing may also matter. Even where everyone intended the land to return, a return after the 30-day period may not meet condition 7.
- Do not confuse the charge being registered at the start with a finding that tax is due.
- Do not assume that a transfer back, by itself, removes the charge.
- Do not overlook the 60% capital-payment condition.
- Do not send evidence before the effective date of the second transfer and expect paragraph 16 to apply.
- Do not treat WRA’s 30-day notice period as a deadline for the issuer to provide evidence.
- The source does not cover the different rules where the bond asset is replaced by other land.
Key takeaways
- The charge can end only after the second transfer has taken effect.
- The bond issuer must prove conditions 1 to 3 and 5 to 7.
- WRA must notify the Chief Land Registrar within 30 days after receiving the evidence.
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
- LTTA 2017 Schedule 11 para 6 — arrangements for transfer and later return of land
- LTTA 2017 Schedule 11 para 7 — bond issuer holds land as a bond asset
- LTTA 2017 Schedule 11 para 8 — income arrangements including a leaseback to original owner
- LTTA 2017 Schedule 11 para 9 — registered charge securing potential tax interest and penalties
- LTTA 2017 Schedule 11 para 10 — minimum capital payments of sixty percent of land value
- LTTA 2017 Schedule 11 para 11 — land held as bond asset until bond ends
- LTTA 2017 Schedule 11 para 12 — return of land within statutory time limits
- LTTA 2017 Schedule 11 para 16 — when land stops being subject to the registered charge
- LTTA 2017 Schedule 11 para 19 — WRA notice to registrar after charge discharge
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 identifies the 2018 Administration Regulations as the source of the evidence requirements, but does not give the regulation number.
- The supplied statutory library does not include a currency notice or a recorded current-to date. The current wording of the legislation and regulations should therefore be checked before relying on a live transaction.
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 statement from the bond issuer, or someone authorised to act for it, confirming that conditions 1 to 3 and 5 to 7 have been met.
- The unique transaction reference number for the return claiming relief on the transfer from the original owner to the bond issuer.
- The unique transaction reference number for the return claiming relief on the transfer back from the bond issuer to the original owner.
- A document supplied by the Chief Land Registrar confirming that the land is registered in the original owner’s name.
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 Removing an LTT charge after an alternative finance bond ends [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 - LTTA 2017 Schedule 11 para 6 - arrangements for transfer and later return of land https://www.legislation.gov.uk/anaw/2017/1/schedule/11/paragraph/6 - LTTA 2017 Schedule 11 para 7 - bond issuer holds land as a bond asset https://www.legislation.gov.uk/anaw/2017/1/schedule/11/paragraph/7 - LTTA 2017 Schedule 11 para 8 - income arrangements including a leaseback to original owner https://www.legislation.gov.uk/anaw/2017/1/schedule/11/paragraph/8 - LTTA 2017 Schedule 11 para 9 - registered charge securing potential tax interest and penalties https://www.legislation.gov.uk/anaw/2017/1/schedule/11/paragraph/9 - LTTA 2017 Schedule 11 para 10 - minimum capital payments of sixty percent of land value https://www.legislation.gov.uk/anaw/2017/1/schedule/11/paragraph/10 - LTTA 2017 Schedule 11 para 11 - land held as bond asset until bond ends https://www.legislation.gov.uk/anaw/2017/1/schedule/11/paragraph/11 - LTTA 2017 Schedule 11 para 12 - return of land within statutory time limits https://www.legislation.gov.uk/anaw/2017/1/schedule/11/paragraph/12 - LTTA 2017 Schedule 11 para 16 - when land stops being subject to the registered charge https://www.legislation.gov.uk/anaw/2017/1/schedule/11/paragraph/16 - LTTA 2017 Schedule 11 para 19 - WRA notice to registrar after charge discharge https://www.legislation.gov.uk/anaw/2017/1/schedule/11/paragraph/19 Guidance page from the Welsh Revenue Authority on this topic (guidance, not law): https://www.gov.wales/land-transaction-tax-alternative-finance-investment-bonds-relief-technical-guidance#6855 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 identifies the 2018 Administration Regulations as the source of the evidence requirements, but does not give the regulation number. - The supplied statutory library does not include a currency notice or a recorded current-to date. The current wording of the legislation and regulations should therefore be checked before relying on a live transaction. 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 3 September 2026
Useful article? You may find it helpful to read the original guidance here: Removing an LTT charge after an alternative finance bond ends
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