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Multiple dwellings relief + subsale relief

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Posted on:
23/04/15 13:59
Subject: Multiple dwellings relief + subsale relief

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?
Justin Bryant

Posted on:
30/07/15 14:36
Subject: RE: Multiple dwellings relief + subsale relief

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.?

There may however be another solution that an STPG member could advise you on.

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