Readers’ forum: Connected companies’ VATable supply and SDLT

We act for a client who owns property in his own name and via three companies. He has indicated he is contemplating the following transactions.

Company A is contemplating acquiring two development plots from the client. It will hold the land as stock in trade with the intention of making first grants of major interests of the buildings that it plans to erect on the plots by effecting disposals to Companies B and C (associated companies under common ownership). Company C (which is a 100% subsidiary of Company B) plans to acquire three leaseholds to be granted by its parent Company B. Company C also plans to acquire seven residential properties from the client. Can readers confirm that under the planned disposals and the undertaking of further development only Company A will be making a vatable supply (albeit to a connected company)?

We would also appreciate readers’ comments...