SDLT on gift to associated company

[johnmarks]

I am non resident and wish to transfer by way of gift some unmortgaged uk residential properties to an offshore company I currently own. One solicitor told me that gifts to associated companies are liable to SDLT but I wonder if he got it wrong and it only applies to transfers for value. It does say in the HMRC document that this does not apply to normal exemptions, and I wonder if a gift is a normal exemption?

I could transfer the offshore company to trustees, and will in due course, but have yet to find offshore trustees who don't charge an arm and a leg.

[section 44]

SDLT would be payable on deemed consideration equal to the market value of the property.