The taxpayer was not entitled to claim a refund of the higher rate of land transaction tax imposed on his acquisition of a residential property in Wales, as the effective date on which he sold his original property was not within three years of the effective date of his purchase of the Welsh property, and there was no discretion at the time to extend the claim period. 

The appellant purchased a residential property in Wales on 28 November 2019. At the time, the appellant owned another residential property in Worcester. Consequently, his purchase of the Welsh property was a ‘higher rate residential property transaction’ and was subject to higher rates of land transaction tax (LTT). The appellant paid LTT on the purchase of the Welsh property. He intended to sell the Worcester property and move to the Welsh property. However, the appellant’s sale of the Worcester property was delayed because: (1) Coronavirus lockdowns imposed from 26 March 2020