The appellant company’s late payment of land transaction tax was not attributable to the Coronavirus pandemic as the penalty date for the tax preceded the start of the Coronavirus ‘lockdown’ restrictions, and there was no reasonable excuse on the facts, or special circumstances.  

On 12 December 2019, the Welsh Revenue Authority (WRA) received a land transaction tax (LTT) return filed online by the appellant company’s solicitors. The return concerned the purchase of a freehold property in Wales, for a total consideration of £3,210,000. The return recorded that LTT was due in the sum of £171,100, which had remained unpaid.

On 4 February 2020, WRA issued a penalty to the appellant for failing to pay the LTT in the sum of £8,555, representing tax at 5% of the LTT. The appellant appealed. 

The appellant’s grounds of appeal were: “i. One of the director [sic] is from overseas and in