05 May 2021
M & M Builders Ltd v HMRC; (UT)
M&M Builders considers the valuation of chargeable consideration for SDLT. It looks in particular at the interaction between two deeming provisions: s 52 (annuities) and s 53 (acquisitions by connected companies). The decision confirms that s 53 takes priority over s 52.
Elizabeth Wilson QC acted for HMRC (Respondents).
To see the approved decision, click here.