LTT enquiries: when WRA can check your tax return
LTT enquiry notices in brief
WRA normally has 12 months to notify you that it is opening an enquiry into an LTT return. The relevant date can change if the return was filed late or you later amended it.
- Keep records of filing, receipt and amendment dates.
- Check whether a notice is about a return already checked.
- A further return for the same transaction can create a limited exception.
Scroll down for the full analysis.
Read the original guidance here:
LTT enquiries: when WRA can check your tax return
For Welsh Land Transaction Tax (LTT), Wales’s form of stamp duty, the Welsh Revenue Authority (WRA) will usually have 12 months to tell you it is checking your tax return. That notice starts an enquiry. It does not, by itself, say that you owe more tax.
What this rule is about
When you file an LTT return, you state whether tax is due and how much you think you must pay. WRA can check that return. The law sets a time window for WRA to begin that check.
This matters because the date is not always the day you sent the return. Late returns can alter that period. Later changes can too.
What the official source says
WRA must issue a notice of enquiry if it wants to open an enquiry into a return. Usually, it must do this within 12 months of the date the return was due, but where WRA received the return later, the 12 months instead run from the day it received it. In that case, receipt sets the period.
- After you amend your return, WRA normally has 12 months from the amendment date to open an enquiry.
- WRA cannot normally open another enquiry into a return it has already checked.
- An exception applies where a further return has been made for the same land transaction.
- For that exception, WRA must have opened an enquiry into the further return.
- WRA must also believe it is necessary to enquire into the earlier return.
- An enquiry may look at whether tax is due at all.
- It may also look at the amount of tax due.
There is a separate rule for a return that WRA has already checked and closed. If you then amend that return, WRA may send a further notice. However, the new enquiry is not a chance to reopen everything.
It can cover only the change you made and matters affected by that change.
What this means in practice
Keep the dates and copies. The due date, WRA’s receipt date and any amendment date may each matter. A notice sent outside the normal enquiry period may need a closer look.
Do not assume an old return is beyond review just because 12 months have passed. A further LTT return for the same land transaction may bring the earlier return back into scope under the special rule.
- Read the notice carefully and keep the envelope or electronic message.
- Check which tax return WRA says it is enquiring into.
- Check the return’s due date and the date it was actually filed.
- Check whether you amended the return after filing it.
- Find any earlier enquiry notice and closure notice.
- If there is a later return, check whether it concerns the same land transaction.
- Match the questions in the notice to the issue WRA is checking.
How to analyse it
Start with timing. Then work through the history of the return. What looks like a simple 12-month question can depend on a later filing or an amendment.
- When was the return due to be filed?
- When did WRA actually receive it?
- Did you amend it, and if so, when?
- Has WRA previously opened and closed an enquiry into this return?
- Has a further LTT return been made for the same land transaction?
- Has WRA opened an enquiry into that later return?
- Does the new notice concern the amendment or something affected by it?
Ask a simple question: which event starts the clock in this case? The answer may be the due date, the receipt date or the amendment date.
Example
Imagine that Priya files an LTT return. WRA later closes an enquiry into it. Priya then changes the return. WRA can issue a new notice within 12 months of that change, but its new check must stay tied to Priya’s amendment and matters changed by it. It cannot use that notice to start again on an unrelated point from the original return.
Why this can be difficult in practice
People often focus only on the original filing date. That can be the wrong date. A late filing and a later amendment each have their own effect on the enquiry period.
The special rule for a further return is also narrow. It is not enough that WRA has another return from you. The later return must concern the same land transaction, WRA must have opened an enquiry into it, and WRA must consider an enquiry into the earlier return necessary.
- A correction by WRA is not the same thing as an amendment made by you.
- Several documents may concern a property deal without amounting to a further return for the same transaction.
- A notice after a closed enquiry may appear broad, even though its legal scope is limited.
- The date a notice was issued can matter as much as the date you read it.
Key takeaways
- WRA normally has 12 months to notify you of an LTT enquiry.
- A late return or your amendment can change when that period starts.
- After closure, later amendments limit further enquiries. Their effects may also be covered.
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 43 — when WRA may give an enquiry notice
- TCMA 2016 section 44 — what an enquiry into a return may cover
- LTTA 2017 Schedule 23 para 12 — amendments to the Welsh enquiry notice rules
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 bundled statutory extract records the amendment to section 43 as introduced, rather than giving a stated consolidation date. The current consolidated wording should be checked before relying on this page for a live deadline.
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 filing due date for the return
- Proof of the date WRA received a late return
- A copy of any amendment and its submission date
- Any notice of enquiry issued by WRA
- Details of any later return for the same land transaction
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 LTT enquiries: when WRA can check your tax return [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 43 - when WRA may give an enquiry notice https://www.legislation.gov.uk/anaw/2016/6/section/43 - TCMA 2016 section 44 - what an enquiry into a return may cover https://www.legislation.gov.uk/anaw/2016/6/section/44 - LTTA 2017 Schedule 23 para 12 - amendments to the Welsh enquiry notice rules https://www.legislation.gov.uk/anaw/2017/1/schedule/23/paragraph/12 Guidance page from the Welsh Revenue Authority on this topic (guidance, not law): https://www.gov.wales/tax-collection-and-management-wales-act-2016-tax-returns-enquiries-and-assessments-technical#5928 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 bundled statutory extract records the amendment to section 43 as introduced, rather than giving a stated consolidation date. The current consolidated wording should be checked before relying on this page for a live deadline. 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: LTT enquiries: when WRA can check your tax return
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