When WRA will not give an opinion on Land Transaction Tax (LTT)
When WRA will not give an LTT opinion
WRA says its LTT opinion service is not for hypothetical questions, incomplete facts, tax planning, or matters already under review.
- Use real and complete transaction facts.
- Contact the case officer if WRA is checking your position.
- Do not treat the service as approval of a tax plan.
Scroll down for the full analysis.
Read the original guidance here:
When WRA will not give an opinion on Land Transaction Tax (LTT)
When WRA will not give an opinion on Land Transaction Tax (LTT)
The Welsh Revenue Authority, or WRA, will not answer every Land Transaction Tax (LTT) question. That matters.
If you are looking for help with stamp duty, remember that LTT replaced Stamp Duty Land Tax in Wales in 2018. An opinion service is not a way to test an idea, approve a tax plan, or reopen an active case.
What this rule is about
Some LTT questions have a clear answer in published guidance. Others turn on the full facts.
WRA says its opinion service deals with genuine uncertainty, not broad questions or tax planning, so you need to show it a real transaction and provide the facts it needs before it can consider an opinion. Otherwise, WRA says it will not provide one.
What the official source says
This is WRA guidance about how it runs its service, not the law that decides your LTT bill, even though it explains the situations in which WRA will not provide an opinion. That distinction matters.
WRA says it will not provide an opinion in these situations:
- The question is about a hypothetical situation.
- You have not provided all the information WRA needs.
- You have already filed an LTT return, unless you are considering an amendment.
- WRA is checking your tax position for that period.
- WRA does not think there is a genuine point of uncertainty.
- You want tax planning advice.
- You want WRA to approve a tax planning product or arrangement.
- You ask about the general anti-avoidance rule.
- You ask how WRA treats a transaction it believes is meant to avoid tax.
What this means in practice
Do not frame the request as “what if we did this?” Instead, give the facts of the transaction that is happening or has happened, including the details that affect the LTT point you need WRA to consider. Be direct.
If WRA is already checking the matter, contact the officer handling that case instead.
- Set out the facts, dates, documents and parties clearly.
- Identify the exact LTT point you cannot work out.
- Say if you have filed a return and are considering changing it.
- Use published guidance where WRA says the answer is already clear.
How to analyse it
Before spending time on a detailed request, ask what actually decides whether WRA can help: a real transaction, full information, and a genuine point that published guidance has not already answered. Start there.
- Is your question about actual facts rather than a possible future plan?
- Have you included every fact that could change the answer?
- Has an LTT return already been filed?
- Is WRA checking the same period or transaction?
- Are you asking for an explanation of the law, rather than approval of a plan?
- Does published WRA guidance already deal with the point?
Example
Rhodri has agreed to buy land in Wales and has the contract, plans and details of the payment, so he asks how LTT applies to those facts rather than whether he could rearrange the deal to reduce tax. That is different.
WRA says it will not give tax planning advice or approve an arrangement.
Why this can be difficult in practice
People often think a question is factual when a key fact is still missing, but a missing agreement, an unclear payment, or an unfinished plan may stop WRA from giving an opinion. Details decide it.
- “Would this work?” can be a hypothetical question, not a request about a real deal.
- An ongoing WRA check changes who you need to contact.
- A request about avoiding tax may raise the general anti-avoidance rule instead.
Key takeaways
- WRA will not answer hypothetical LTT questions.
- Give complete facts about a real transaction.
- WRA will not approve tax planning arrangements.
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 section 66 — inserts the Welsh general anti-avoidance rule
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 source does not define what WRA will regard as a genuine point of uncertainty.
- The source does not set out the information needed for every type of request.
- The source does not explain how WRA decides that a transaction is intended to avoid tax.
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 actual transaction documents and agreed facts
- a complete account of the parties and steps involved
- details of any LTT return already filed
- details of any current WRA check or named case officer
- the precise question that remains uncertain
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 When WRA will not give an opinion on Land Transaction Tax (LTT) [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 section 66 - inserts the Welsh general anti-avoidance rule https://www.legislation.gov.uk/anaw/2017/1/section/66 Guidance page from the Welsh Revenue Authority on this topic (guidance, not law): https://www.gov.wales/welsh-revenue-authority-tax-opinion-service#50042 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 source does not define what WRA will regard as a genuine point of uncertainty. - The source does not set out the information needed for every type of request. - The source does not explain how WRA decides that a transaction is intended to avoid tax. 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: When WRA will not give an opinion on Land Transaction Tax (LTT)
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