If a developer takes possession of a site does a SDLT liability arise?

[Patrick Cannon]

You may find that SDLT is due on the full anticipated consideration (s51) and an application to defer on the balance of the site could be considered (s90). S44A does not have any connected party or market value provisions and so you might as an alternative think about rearranging how the developer goes about this so that for example the right to nominate purchasers is with say B2 for a small turn while B1 is rewarded with a building contract giving it the appropriate share of the profits.

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