LTT determinations when a Land Transaction Tax return is missing
LTT determinations at a glance
The WRA can calculate tax where it believes an LTT return was due but was not filed. A notice requires payment within 30 days, although a later return may replace the calculation if filed by the stated deadline.
- Check the notice date and payment deadline.
- Check the filing date the WRA used.
- File a later return within the applicable time limit.
Scroll down for the full analysis.
Read the original guidance here:
LTT determinations when a Land Transaction Tax return is missing
LTT determinations when a Land Transaction Tax return is missing
If you miss a Land Transaction Tax (LTT) return, the Welsh Revenue Authority (WRA) can work out an amount of tax itself and send you a notice. The WRA calls this a WRA determination. It can mean a payment is due before you have filed your own return.
What this rule is about
A return tells the WRA about a land transaction and the tax due, so without one by the date it thinks applied, it may not wait indefinitely. It can make its own calculation.
That calculation is not necessarily the final answer. You can still file a return afterwards, if you meet the time limits. But the notice creates an urgent payment issue: the source says payment is due within 30 days.
What the official source says
According to the official WRA technical source, it may make a determination when it believes tax is due and a person has not filed a return by the relevant filing date. Its determination states the amount the WRA believes is payable.
- It must notify you of the determination.
- You must pay the amount stated within 30 days after the WRA issues the notice.
- It cannot make a determination more than four years after the relevant filing date.
- For this purpose, the relevant filing date is the date by which the WRA believes the return should have been made.
- A return filed later can replace the determination.
In the source, the later return is called a self-assessment. In simple terms, that is your own tax return and calculation. Once it validly replaces the determination, the tax shown on your return becomes the amount that matters.
What this means in practice
Do not treat a WRA determination as a reminder that can wait. Rather than being a reminder, it is a formal calculation of tax, and the source says you must pay the amount within 30 days. Check the notice date straight away.
Filing a return later may correct the position. Even so, filing one does not remove the need to consider any unpaid amount or recovery action already under way.
- Keep the determination notice, including the date the WRA issued it.
- Check why the WRA says you needed to file an LTT return.
- Work out the relevant filing date used by the WRA.
- Prepare and file your own return before the later-return deadline expires.
- Check whether the WRA has started steps to recover the amount.
How to analyse it
Start with the missed return, not the amount on the notice. Ask when the WRA believed you had to file the return. That date controls both its power to make a determination and one of the deadlines for replacing it.
- Was an LTT return required for the transaction?
- Did the WRA believe tax was due?
- Had you filed no return by the filing date it believed applied?
- Did the WRA issue the determination within four years after that date?
- What is the 30-day payment deadline shown by the notice date?
- Have you now filed a return?
- Was it filed by the later of four years after the relevant filing date and 12 months beginning with the notice date?
- Were recovery proceedings already underway when the return was filed?
Example
Because the WRA believes Mina should have filed an LTT return but did not, it sends her a determination stating that tax is due. The notice says that tax is due.
She must deal with the stated amount within 30 days of the notice being issued.
Mina later files her own return. If she files it by the later deadline in the official source, her return replaces the determination.
If the WRA had already begun recovery action and it was still ongoing when Mina filed, that action may continue for any unpaid tax shown by Mina’s return.
Why this can be difficult in practice
Different dates do different jobs. The date a return was due is not always the notice date. The deadline for payment is also separate from the deadline for filing a later return.
People may also assume that filing a late return ends all action at once. The source does not say that.
Instead, it says ongoing recovery proceedings may continue as proceedings to recover unpaid tax shown by the later return.
- A notice may use a filing date you need to check carefully.
- The four-year limit concerns when the WRA may make a determination.
- The later-return deadline uses two alternative dates and takes the later one.
- Filing a return does not necessarily end recovery action already in progress.
Key takeaways
- A missing LTT return can lead to a WRA determination.
- The notice amount is due within 30 days of issue.
- A later return can replace the determination if filed in time.
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.
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.
- WRA TCMA/1090 WRA Determinations — WRA guidance on missing tax returns and determinations
Where this is not settled
- The supplied statutory library does not include the Tax Collection and Management (Wales) Act 2016 provisions behind this guidance. The exact statutory section references and their current wording need checking.
- No currency-notice.md was available in the mounted skills, so the current status of the statutory rules could not be verified from the supplied materials.
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 WRA notice and its issue date.
- The date on which the LTT return was due.
- Any LTT return filed after the determination.
- Records showing whether recovery proceedings have started or concluded.
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 determinations when a Land Transaction Tax return is missing [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.] 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#5938 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 statutory library does not include the Tax Collection and Management (Wales) Act 2016 provisions behind this guidance. The exact statutory section references and their current wording need checking. - No currency-notice.md was available in the mounted skills, so the current status of the statutory rules could not be verified from the supplied materials. 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
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