To all the SDLT whizzes out there. I am buying a piece of land for development, intending to build there 10 flats. I understand that the purchase of the land is not eligible for multiple dwellings relief since no construction work has yet begun. What about if I interposed a company as an intermediary purchaser, who buys the land and then sells it on to the ultimate purchaser as an off-plan sale of the 10 flats which are yet to be built (which I gather is eligible to multiple dwellings relief as per SDLTM29960). Can I claim sub-sale relief on the first transfer to enable me to claim multiple dwellings relief on the second?
I think you would need to worry about the following extract from the link below:
?Relief is barred where it is reasonable to conclude that the transferor had a main purpose of securing a tax advantage for any person. In the definition of tax advantage, ?tax? refers only to SDLT and not other taxes.?