Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017 section 12

Amendments to the notice of enquiry provisions

Schedule 23 paragraph 12 amends the rules governing when the Welsh Revenue Authority (WRA) may open an enquiry into a land transaction tax return, introducing a defined enquiry period and a new power to revisit earlier returns when a further return is made for the same transaction.

• WRA must normally open an enquiry into a tax return within a 12-month enquiry period starting from the relevant date.
• WRA may enquire into an earlier land transaction tax return outside the 12-month period if a further return has been made for the same land transaction, WRA has opened an enquiry into that further return, and WRA considers it necessary to also examine the earlier return.
• Where WRA opens a late enquiry — either because the return was amended by the taxpayer under section 41 or because of the new power relating to further returns — the enquiry period is effectively extended.
• A "further return" for these purposes means any additional return made under the Land Transaction Tax Act (LTTA), for example a return arising from a later linked transaction or a deferred consideration event.