Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017 Schedule 16 paragraph 14

Recovery notice procedure for unpaid group relief tax

Schedule 16 paragraph 14 sets out the procedure by which the Welsh Revenue Authority (WRA) can issue a notice to another group company or controlling director requiring them to pay land transaction tax that remains unpaid following the withdrawal of group relief.

• WRA may issue a notice requiring a responsible person (another group company or controlling director) to pay the outstanding tax amount within 30 days of the notice being issued.
• The notice must be issued within 3 years of the date on which the tax liability was finally determined.
• The notice must clearly state the amount the person is required to pay, and that amount is treated as a "relevant amount" under the Tax Collection and Management (Wales) Act 2016, meaning WRA can use its standard payment and enforcement powers to collect it.
• A person who pays an amount under such a notice has a right to recover that amount from the original buyer of the land.