The Land Transaction Tax (Modification of Relief for Acquisitions Involving Multiple Dwellings) (Wales) Regulations 2026: integrated impact assessment

This Integrated Impact Assessment (IIA) relates to the following draft statutory instrument (SI), which the Cabinet Secretary for Finance and Welsh Language laid in the Senedd on 20 January 2026:

“The Land Transaction Tax (Modification of Relief for Acquisitions Involving Multiple Dwellings) (Wales) Regulations 2026”.

The draft SI can be found here:

The Land Transaction Tax (Modification of Relief for​ Acquisitions Involving Multiple Dwellings) (Wales)​ Regulations 2026

Alongside the draft SI, the Cabinet Secretary for Finance and Welsh Language also published an Explanatory Memorandum (EM), which includes a Regulatory Impact Assessment (RIA). The EM can be found here:

Explanatory Memorandum to The Land Transaction Tax (Modification of Relief for Acquisitions Involving Multiple Dwellings) (Wales) Regulations 2026

The EM and draft SI set out the amendment which the Welsh Government is proposing to the Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017 (LTTA), to make the following change to rules governing land transaction tax (LTT) multiple-dwellings relief (MDR):

• an increase in the rate of the MDR minimum tax rule from 1% to 3%.

Consultation

There is no statutory duty to consult on the proposals set out here. The Welsh Government consulted the public on MDR and other matters concerning LTT reliefs between 8 April and 19 May 2024. The legislative proposals set out in this IIA are part of the response to that consultation and follow-on from the legislative changes introduced in February 2025 (Explanatory Memorandum to The Land Transaction Tax (Modification of Relief for Acquisitions Involving Multiple Dwellings) (Wales) Regulations 2025). The Welsh Government is not conducting additional public consultation at this time on these matters. (See also para. 1.34 to 1.43, ‘Consultation’.)

Impact and the proportionate approach

It is anticipated the proposed change will increase fairness in the tax treatment of multiple-dwelling transactions, and may lead to marginal increases in revenue.

In accordance with Welsh Government practice, a proportionate approach is taken in this IIA, which summarises the Welsh Government view that the proposed changes are anticipated to have positive impact and minimal, if any, negative impact.

1.1 The information provided in this section is also found in the Explanatory Memorandum which is published on the Senedd website:

Explanatory Memorandum to The Land Transaction Tax (Modification of Relief for Acquisitions Involving Multiple Dwellings) (Wales) Regulations 2026

Description of purpose and intended effect of the proposal

1.2 The Welsh Government is proposing the following change to the rules governing the land transaction tax (LTT) Relief for Acquisitions Involving Multiple Dwellings, also known as Multiple-Dwellings Relief (MDR):

• an increase to the rate at which the MDR minimum tax rule is set, from 1% to 3%.

1.3 The change will be made through amending Schedule 13 of the Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017 (the LTTA).

1.4 The amendment will improve the LTTA in line with the Welsh Government’s tax principles, which state that Welsh taxes should:

1. Raise revenue to fund public services as fairly as possible
2. Deliver Welsh Government policy objectives
3. Be clear, stable and simple
4. Be developed through collaboration and involvement, and
5. Contribute directly to the Well-being of Future Generations Act goal of creating a more equal Wales.

1.5 The proposal follows legislative changes made in February 2025 to improve MDR rules. At that time the Welsh Ministers announced the intention to further monitor and consider the role of MDR, and that it would be subject to further decisions as appropriate (Explanatory Memorandum to The Land Transaction Tax (Modification of Relief for Acquisitions Involving Multiple Dwellings) (Wales) Regulations 2025, 14 January 2025).

Legislative background

1.6 The UK government (UKG) introduced MDR into stamp duty land tax (SDLT) legislation in 2011, with the aim of reducing a potential barrier to investment in residential property, to support housebuilders following the financial crash and to promote housing supply from the private rented sector (PRS). With marginal changes, MDR was carried over into LTT legislation in 2018.

1.7 The UKG abolished SDLT MDR on 1 June 2024, stating it had a:

“minimal positive impact on overall housing supply or PRS supply”, and that it was “not cost effective in meeting its original objectives.

1.8 The Welsh Government then consulted the public on the option of abolishing LTT MDR (8 April to 19 May 2024), as part of a wider consultation on LTT reliefs (see below, Section 5. Consultation).

1.9 Subsequently, in January and February 2025, the Welsh Government proposed, and the Senedd agreed, amendments to the rules governing LTT MDR to discontinue the possibility for taxpayers to benefit from both MDR and the Subsidiary Dwelling Exception in the same multiple-dwelling transactions liable to the higher residential rates.

1.10 When proposing legislative changes in January 2025, the Welsh Government set out that MDR would be subject to further consideration during the course of 2025. The current proposal is the result of that further consideration.

1.11 Section 30 of the LTTA introduces Schedules 9 to 22 which make provision for reliefs that can be claimed in respect of certain transactions normally liable to LTT. Schedule 13 provides for relief for acquisitions involving multiple dwellings, also known as multiple-dwellings relief, or MDR. Under section 30(6)(b), the Welsh Ministers may amend the LTTA by regulations to modify a relief to LTT. Regulations made under section 30(6) of the LTTA are subject to the draft affirmative procedure.

1.12 Under Section 78 of the LTTA, the Welsh Ministers may also by regulations make such incidental, consequential, supplemental, transitional, transitory or saving provision as they think appropriate for the purposes of, or in connection with, or for giving full effect to, any provision made by or under this Act. These regulations will include transitional provisions to provide clarity on applicable MDR rules for land transactions; effected in pursuance of a contract (or a contract that is substantially performed) before the rule changes and completed after, and, where there are linked transactions either side of these new rules coming into force.

Purpose and intended effect of the legislation

1.13 The regulations will make one amendment to the LTTA.

1.14 It is anticipated the amendment will improve fairness in the treatment of multiple-dwelling transactions. The changes may marginally increase LTT revenues to the Welsh Government.

Current rules

1.15 MDR is a partial relief of LTT, which can be claimed by a taxpayer when they acquire more than one dwelling from the same seller, in a single transaction or in linked transactions. Taxpayers are under no obligation to claim MDR. If MDR is claimed, the taxpayer calculates and pays tax according to the formula set out in the LTTA (see below, paragraph 1.19).

1.16 Claims are made in LTT self-assessments and are checked by the WRA. As an example, a purchase of 4 dwellings together costing £1 million would be liable to a LTT charge of £111,200 without MDR, or £59,800 with MDR (based on the rates in force on 1 October 2025).

1.17 MDR is applied differently in the following 2 categories of transaction:

• residential property transactions, in which only dwellings are sold/purchased
• mixed-use transactions, in which the property sold/purchased consists of both residential and non-residential portions.

1.18 In residential property multiple-dwelling transactions, MDR is applied to whole cost of the transaction, which is liable at the LTT higher residential rates. In mixed-use transactions, MDR is applied to the residential portion only, which is liable at the LTT main residential rates (the non-residential portions are liable at non-residential rates).

1.19 Calculating MDR in residential property transactions. Residential property multiple-dwelling transactions are subject to the LTT higher residential rates. When MDR is claimed, the following calculation formula is used to establish LTT liability on the whole transaction:

Example

(calculations based on LTT rates in force in October 2025)

• Purchase of 4 dwellings in the same transaction.
• Total cost £1million.
• The dwellings would cost £200K, £225K, £250K and £325K if purchased separately.
• Average price of dwelling £250K.
• The purchaser may choose to claim MDR.

Note. Minimum Tax Rule. In rare cases in which the liability calculated by the calculation method above arrives at a sum which is less than 1% of the value of the dwellings purchased, the minimum tax rule is applied so that the liability then becomes the rate at which the minimum tax rule is set. The rate is currently 1%. (See also paragraph 1.25)

1.20 Calculating MDR in mixed-use transactions. As set out initially in paragraph 4.6, LTT liability is generally lower in mixed-use multiple-dwelling transactions than in residential property multiple-dwelling transactions, for two reasons.

1.21 First, while residential property multiple-dwelling transactions are subject to the more expensive LTT higher residential rates, in mixed-use multiple-dwelling transactions, the residential portions of transactions, on which MDR is claimed, are subject to the less expensive main residential rates.

1.22 Second, non-residential portions of mixed-use transactions are liable at the less expensive non-residential rates.

1.23 The process of establishing liability in mixed-use multiple-dwelling transactions is more involved than that used in residential property multiple-dwelling transactions. This reflects the need to provide fairness in taxing transactions which can potentially encompass wide differences in value between residential and non-residential portions.

1.24 The following 5 steps are taken to calculate liability:

1. Apportionment, to establish what part of the total cost is for the residential and non-residential portions respectively
2. Calculation of liability for the residential portion: the LTT main residential rates are applied to the MDR calculation formula, where MDR is claimed
3. If MDR is claimed, the MDR Minimum Tax Rule must be considered and either applied or not: if the liability for the residential portion alone as calculated above comes to less than 1% of the cost of that portion, the liability for that portion is then set at 1% of the total cost of that portion
4. Calculation of liability for the non-residential portion (see detail below)
5. Addition: the liability for the 2 portions is added to arrive at the total liability.

1.25 MDR Minimum tax rule. This rule exists to increase fairness in tax treatment, by preventing the possibility that dwellings in mixed-use multiple-dwelling transactions could be exchanged tax-free. Tax-free treatment would occur because of the combination of these 2 factors:

1. the LTT main residential rates apply in this category of transaction, and
2. there is a threshold below which dwellings can be purchased without paying LTT, when they are subject to the main residential rates – this is currently £225,000.

This tax-free treatment would be unfair by comparison with residential property multiple-dwelling transactions. The minimum tax rule therefore provides an element of rebalancing and fairness between residential and mixed-use multiple-dwelling transactions.

1.26 Establishing liability on the non-residential portion. This is calculated by the following 3 steps;

1. calculate the notional liability for the whole transaction (residential and non-residential portions combined) according to the non-residential rates
2. calculate the percentage proportion of the full transaction price attributable to the non-residential portion, as follows, cost of non-residential portion / full cost
3. calculate the total liability for the non-residential portion by multiplying the sums arrived at in steps i. and ii. above.

Example

A £600,000 purchase of a ground floor shop and 2 flats above.

Calculation of liability follows the 5-step approach (see paragraph 1.15 above).

1. Apportionment: shop worth £250,000; 2 flats worth £350,000 combined (£150,000 and £200,000 each).
2. Liability on the residential portion = £3,500
   • notional average price of the dwellings = (£200k + £150k)/2 = £175k
   • £175k is below the LTT main residential rates starting threshold of £225k, therefore no LTT is due by this stage in the calculation.
3. Given the result in Step ii., the MDR Minimum Tax Rule is applied, giving the liability on the residential portion as 1% of £350k = £3,500.
4. Liability on the non-residential portion = £7,396
   • notional liability for the whole transaction (residential and non-residential portions combined) according to the non-residential rates = £17,750
   • proportion of the full transaction attributable to the non-res. portion = 41.67%
   • total liability for the non-residential portion = £17,750 x 41.67% = £7,395.83
5. Total liability, £600K mixed-use transaction = £3,500 + £7,396 = £10,896

Proposed amendments to the LTTA

1.27 The regulations will make 2 changes to the LTTA as follows:

1. for residential property multiple-dwelling transactions subject to the LTT higher residential rates: a new MDR Equalisation Rule will be introduced, so that total liability in multiple-dwelling transactions will be calculated by adding the individual liabilities otherwise incurred were the same dwellings to be purchased separately

and

2. for mixed-use multiple-dwelling transactions subject to the LTT main residential rates: the rate of the MDR minimum tax rule will increase from 1% to 3%.

1.28 Transitional rules will apply, so that transactions entered into but not completed before the date the new Regulations come into force, will be subject to the rules previously in force.

1.29 Increasing the MDR Minimum Tax Rule Rate from 1% to 3%. Currently, there is a significant difference between the levels of tax liability in mixed-use and residential property multiple-dwelling transactions. Liability can be significantly lower in mixed-use transactions for the 2 reasons that the residential portion is liable to the LTT main residential rates (whereas residential-only transactions are liable to the higher residential rates) and that the non-residential portion is liable to the lower non-residential rates.

1.30 The Welsh Government is content that an advantageous treatment, with lower levels of liability, should prevail for mixed-use transactions. However, the difference between liability levels for these 2 categories should be reduced, to reflect the need to increase fairness.

1.31 This change may marginally increase LTT revenues to the Welsh Government, which will support the funding of public services. The Welsh Government believes the increases in liability brought about by the proposed increase will ensure reasonable and proportionate tax contributions.

Consultation

1.32 The Welsh Government consulted the public on MDR and other questions related to LTT reliefs between 8 April and 19 May 2024.

1.33 The consultation document can be found here: Proposed changes to land transaction tax reliefs

1.34 On MDR, the following questions were asked:

• Question 1.1 Do you agree the proposal to abolish LTT MDR set out in this consultation aligns with the Welsh Government’s tax principles?
• Question 1.2 Do you think the abolition of LTT MDR will negatively impact the private rented sector in Wales?
• Question 1.3 Do you think the abolition of LTT MDR will negatively impact any others in Wales?

1.35 The Welsh Government published a summary report on the consultation on 17 July 2024. It can be found here: Proposed changes to land transaction tax reliefs. In the report, the Welsh Government gave an undertaking to conduct a further assessment of the options with regard to MDR, taking account of the comments received, and to provide an update on plans in due course.

1.36 Several respondents declared a direct or indirect interest in LTT MDR. Many respondents who argued for retaining MDR cited commercial reasons. Some felt that abolishing MDR would disincentivise investment in property rental sectors, which could lead to declines in housing supply and the wider Welsh economy. Some emphasised the importance to housing supply of sectors which benefitted from MDR, such as the private rented sector, the purpose-built student sector and the build to rent sector. Some argued for enhancing, developing or otherwise improving MDR rather than abolition.

1.37 Some supporting the abolition of MDR mentioned the budgetary pressure on the Welsh Government created by the previous UKG abolition of SDLT MDR. Some noted that abolishing MDR would support tax simplification. Some observed that tax reliefs are often poorly understood by taxpayers and can lead to inappropriate calculations, claims being challenged by the respective tax authorities and unsuccessful appeals to the tax tribunal. Some felt that abolishing LTT MDR would bring about symmetry across the devolved tax border (following the UKG abolition of SDLT MDR for England and Northern Ireland) and thereby aid simplification.

1.38 Some responses emphasised the importance of decision making in the wider context of the Welsh Government’s commitments to the Wellbeing of Future Generations and housing policy, and the importance of an evidence base to support the introduction of changes to the LTT regime.

1.39 Following the consultation, the Welsh Government further developed MDR policy. Additional consideration was given to the option of amending MDR rules so as to remove the opportunity to claim MDR and SDE in the same transaction, alongside the options of retention and abolition.

1.40 In January 2025 the Welsh Government set out the proposals to amend MDR rules (Explanatory Memorandum to The Land Transaction Tax (Modification of Relief for Acquisitions Involving Multiple Dwellings) (Wales) Regulations 2025). The Senedd approved these proposals, and the changes came into force on 10 February 2025.

1.41 At that time, the Welsh Government said, as it was anticipated that the value of MDR would increase over time, and against the background at the time for public finances, the Welsh Government would retain MDR in the longer-term only if it had confidence that it was likely to remain an appropriate policy lever and provide value for money. Therefore, MDR would continue to be monitored, and would be subject to further decisions as appropriate.

Policy considerations

1.42 The Welsh Government has decided to retain and further improve MDR because it is a policy lever which, by offering benefits to the PRS, may support the delivery of housing commitments. These commitments are set out in the Welsh Government’s Consultation on the White Paper on securing a path towards Adequate Housing, including Fair Rents and Affordability (October 2024):

“We are acutely aware of … the importance of the Private Rented Sector in providing a range and choice of accommodation for families and individual households … numbers of people presenting to homelessness services and supported with temporary accommodation continue to rise. As we continue to face uncertain times and ongoing financial pressures it is critical we continue our work to increase access to, and the affordability of, all housing tenures to meet the housing needs of everyone across Wales.”

1.43 The Welsh Government recognises MDR bears a certain cost, in that it is drawn from LTT revenues which support the public services. The Welsh Government recognises that it is not possible to objectively ascertain whether MDR is a determining factor which aids PRS businesses to support Welsh Government housing commitments. And therefore, it is not possible to know with certainty the precise balance of benefit and cost of retaining MDR. However, MDR is clearly a potential benefit to the PRS, and may assist businesses to provide housing, including in cases when ownership of portfolios of dwellings must be transferred in order for the dwellings to remain viable.

1.44 Since 2018, the Welsh Government has provided over £79 million in relief through MDR. MDR may increase over time , and relieved LTT has tended to be somewhat volatile annually. As at least some part of this sum is potentially revenue which would otherwise support the public finances, and in particular against the background of challenging times for public spending, it is important to ensure MDR is a valuable policy lever and represents value for money. It will therefore be important for MDR to be re-evaluated again in future, to ensure it remains on balance a beneficial measure.

2.0 The main positive impact of this measure on social well-being will come as a result of the improvement in fairness in tax treatment in multiple-dwelling transactions. The change may also lead to marginal increases in Welsh Government tax revenue which will contribute to supporting policies which aim to improve social well-being.

2.1 People and Communities

The rule change will apply to relevant homebuyers in all parts of Wales and will increase costs for some taxpayers. However, the pre-existing benefits of LTT MDR, which support taxpayers to achieve reduced liability, are largely retained.

2.2 Children’s Rights

See also the abbreviated Children’s Rights Impact Assessment (CRIA) at Annex A below. A full CRIA has not been completed as the initial, abbreviated CRIA indicates that the proposed changes are not likely to directly impact Children’s Rights.

2.3 Equality

See also the Equality Impact Assessment at Annex B below. No differential impacts on equality are anticipated.

2.4 Rural Proofing

A Rural Proofing Impact Assessment is not required because this proposal is not anticipated to provide relative advantage to either rural or urban taxpayers.

2.5 Health

A Health Impact Assessment is not required because the proposed change is not anticipated to have differential health impacts on particular groups. The Welsh Revenue Authority (WRA) will issue guidance explaining the change in accessible formats, to support those for whom communication is challenging because of health issues.

2.6 Privacy

A Data Protection Impact Assessment is not required because the proposed change will not involve new ways of processing information.

3.1 Cultural Well-being

The proposed change is not anticipated to impact the promotion and protection of culture and heritage, or the ability of people to participate in arts, sport and recreation.

3.2 Welsh Language

The proposed changes are not anticipated to impact the Welsh language. See also the Welsh Language Impact Assessment at Annex C below.

4.1 Business, the general public and individuals

4.4.1 The proposed change may increase costs for some taxpayers. However, the pre-existing benefits of LTT MDR, which support taxpayers to achieve reduced liability, are largely retained.

4.1.2 The measure is not anticipated to significantly disadvantage those involved in the commercial aspects of property transactions such as estate agents, conveyancers and solicitors.

4.2 Public Sector including local government and other public bodies

No differential impact is anticipated.

4.3 Third Sector

No differential impact is anticipated.

4.4 Justice Impact

A minor impact is possible. Please see the Justice Impact Assessment at Annex F below.

5.1 No impact is anticipated on environmental well-being from the proposed change. See also the Biodiversity Impact Assessment at Annex D below.

5.2 The following assessments are not required as the proposed new rule will not impact on the matters which they consider:

• Natural Resources Assessment
• Climate Change Assessment
• Strategic Environmental Assessment
• Habitats Regulations Assessment
• Environmental Impact Assessment.

6.1 Public consultation was conducted on issues related to LTT reliefs, between 8 April and 19 May 2024. The consultation document and the Welsh Government report on the consultation responses can be found here:

Public consultation on land transaction tax reliefs

Welsh Government consultation: summary of responses

6.2 Consultation responses represented a range of views in relation to the Welsh Government proposals and other issues to do with LTT reliefs. The proposals outlined in this IIA partly address some of the issues set out in the consultation.

6.3 The positive impacts of the proposals outlined in this IIA are expected to be improved fairness in the tax treatment of multiple-dwelling transactions and in addition the possibility of a marginal increase in Welsh Government tax revenue. These may have a positive impact on socio-economic disadvantage.

Annex A: Children’s rights

Annex B: Equality

Annex C: Welsh Language

Annex D: Biodiversity

Annex E: Socio-economic Duty

Annex F: Justice

Regulatory Impact Assessment – see Explanatory Memorandum (Explanatory Memorandum to The Land Transaction Tax (Modification of Relief for Acquisitions Involving Multiple Dwellings) (Wales) Regulations 2026)

The Welsh Government believes that, as set out in this IIA, the proposed new tax rule will not adversely disadvantage taxpayers purchasing more than one dwelling in the same, or in linked, transactions. It will introduce fairer tax treatment and may lead to a marginal increase in Welsh Government tax revenue, which will support the public finances.

A. Children’s Rights Impact Assessment

The new rules will improve fairness in the tax treatment of multiple-dwelling transactions, and may marginally increase tax revenue.

The proposed amendments will largely retain MDR, which may support private rental sector (PRS) businesses to maintain or increase the numbers of dwellings in use, in turn supporting the housing, and continuity of housing, of households. It is possible this may indirectly support families in their efforts to care for their children.

The increase in tax revenue may directly or indirectly benefit children who are beneficiaries of services provided by the Welsh Government or others funded by the Welsh Government.

Benefit may be experienced in the context of the following UN Convention on the Rights of the Child (UNCRC) Articles:

UNCRC Article 9 – Separation from parents

Children should not be separated from their parents unless it is for their own good, for example if a parent is mistreating or neglecting a child. Children whose parents have separated have the right to stay in contact with both parents, unless this might hurt the child.

UNCRC Article 19 – Protection from violence, neglect and abuse

Governments should ensure that children are properly cared for, and protect them from violence, abuse and neglect by their parents or anyone else who looks after them.

UNCRC Article 27 – Adequate Standard of living

Every child has the right to a standard of living that is good enough to meet their physical and social needs and support their development. Governments must help families who cannot afford to provide this.

B. Equality Impact Assessment

1. No differential impact is expected from the proposed new rules on any people with protected characteristics as described in the Equality Act 2010.
2. The Welsh Revenue Authority (WRA) will implement and deliver a service with regard to protected characteristics.
3. The WRA will monitor and report on issues to do with accessing its services.
4. No differential impact is expected from the new rules on human rights, UN Conventions, EU/EEA and Swiss citizens’ rights, residency rights, mutual recognition of professional qualifications, access to social security systems, or workers’ rights.

C. Welsh language impact assessment

1. The new rules are not expected to differentially impact the Welsh Language.
2. The WRA is the body responsible for advising taxpayers on the operation of devolved taxes. The WRA complies with the Welsh Language standards and treats the Welsh and English languages equally. The introduction of the new rules is an opportunity to reaffirm this practice and ensure taxpayers in Wales can continue to communicate in both languages regarding their tax affairs.

D. Biodiversity Impact Assessment

The proposed new rules are not expected to have a differential impact on biodiversity.

E. Socio-economic duty assessment

No disadvantageous socio-economic impact is anticipated from the proposed new rules. The MDR Equalisation Rule will increase fairness in tax treatment by ensuring per-dwelling tax liability on multiple-dwelling transactions is equal to the per-dwelling liability in the equivalent single-dwelling transactions. Therefore, it is possible this new rule may have a higher value to those experiencing socio-economic disadvantage.

The proposed new rules will be equally applicable to all eligible taxpayers, regardless of socio-economic circumstances.

F. Justice impact assessment

1. A minor impact on the justice system is considered possible, but unlikely.

2. Welsh Ministers and the Senedd from time to time make changes to devolved land tax legislation. The relevant authority for devolved Welsh land taxes is the Welsh Revenue Authority (WRA). Across the UK, taxpayers who disagree with decisions made by the relevant tax authorities may appeal to the First Tier Tribunal (Tax), which is administered by the UK government’s Ministry of Justice. Therefore, the Welsh Government, when introducing changes to devolved tax legislation, must inform the Ministry of Justice of its assessment of the likely impact of any proposed changes on Tribunals.

3. The Welsh Government has informed the Ministry of Justice of its assessment that the impact of the proposed changes on the First Tier Tribunal (Tax), in terms of the number of appeals which may reach it, will be nil or extremely low, for the following reasons:

• the proposed amendments to the LTTA will give a high degree of clarity regarding rule changes
• the WRA will update existing guidance for taxpayers, including on rights of appeal, and directly contact registered agents to signpost the change to the LTTA
• the WRA will continue to practice well-established measures to address taxpayer disagreements and disputes, including the right to an initial WRA review, and signpost where appropriate to Alternative Dispute Resolution processes
• it is anticipated the numbers of transactions affected by the proposed changes will be low, given that the average number of MDR claims has heretofore been around 400 per year from a total 55,000 LTT transactions, and that the transactions impacted by the changes are likely to be a small minority of those, with the cases reaching the Tax Tribunal, if any, representing an even smaller number.