Tax Collection and Management (Wales) Act 2016 section 43

Notice of enquiry

Section 43 sets out the rules governing when and how the Welsh Revenue Authority (WRA) may open an enquiry into a tax return, including the time limits that apply.

  • WRA may enquire into a tax return only if it issues a notice of enquiry to the taxpayer within 12 months of the relevant date
  • The relevant date is either the filing date or the date the return was actually made (if later), but if the taxpayer amends the return, the relevant date resets to the date of amendment
  • A return that has already been the subject of one enquiry notice generally cannot be enquired into again, unless the taxpayer has amended the return or the late enquiry exception for land transactions applies
  • WRA may open a late enquiry into an earlier land transaction return if a further return has been made for the same transaction, WRA has opened an enquiry into that further return, and WRA believes it is necessary to also examine the original return

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