The First-tier Tribunal has held, in Hannah and another v HMRC [2019] UKFTT 342 (TC) (30 May 2019), that an SDLT scheme seeking to rely on section 52 of the Finance Act 2003 (calculation of chargeable consideration in the case of annuities) failed because the annuity did not, on the facts, constitute the true chargeable consideration for the land transfer.