In The Lower Mill Estate Limited v HMRC [2010] UKUT B25 (TCC), the Upper Tribunal found that (contrary to the First-tier Tribunal), where two commonly-owned companies contracted separately with a purchaser for the standard-rated supply of land and the zero-rated building of a holiday home on that land, that arrangement could not be redefined as a single, standard-rated supply of a completed holiday home under the Halifax principle.