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SDLT—annuity did not prevent market value rule applying (M&M Builders v HMRC)

SDLT—annuity did not prevent market value rule applying (M&M Builders v HMRC)
Published on: 06 May 2021
Published by: LexisPSL
  • SDLT—annuity did not prevent market value rule applying (M&M Builders v HMRC)
  • Why it matters
  • Case details

Article summary

Tax analysis: In M&M Builders (Norfolk) Ltd v HMRC the Upper Tribunal (UT) upheld the decision of the First-tier Tax Tribunal (FTT) that the market value provisions in section 53 of the Finance Act 2003 (FA 2003) applied to calculate the chargeable consideration for a transfer to a connected company in exchange for the grant of an annuity. FA 2003, s 53 was not prevented from applying because the consideration was an annuity. or take a trial to read the full analysis.

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