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

Relevant trustees: appeals and reviews

10 (1) The agreement of all the relevant trustees is required if a settlement agreement relating to the transaction is to be entered into under section 184 of TCMA.

(2) A notice of request under section 173 of TCMA may be given by any of the relevant trustees.

(3) Where WRA undertakes a review of an appealable decision relating to the transaction following such a request made by some (but not all) of the relevant trustees—

(a) notice of the review must be issued by WRA to each of the other relevant trustees whose identity is known to WRA;

(b) any of the other relevant trustees may be a party to the review if they notify WRA in writing;

(c) notice of WRA’s conclusions under section 176(5), (6) or (7) of TCMA must be issued to each of the relevant trustees whose identity is known to WRA;

(d) section 177 of TCMA (effect of conclusions of review) applies in relation to all of the relevant trustees.

(4) In the case of an appeal under Part 8 of TCMA relating to the transaction—

(a) the appeal may be brought by any of the relevant trustees;

(b) notice of the appeal must be issued by WRA to each of the relevant trustees who are not bringing the appeal and whose identity is known to WRA;

(c) any of the relevant trustees are entitled to be parties to the appeal;

(d) the tribunal’s determination under section 181 of TCMA binds all the relevant trustees.