In a system with a sVDEV, no.
The reason being that the sVDEV already brings all the benefits of a persistent, metadata-only L2ARC (and does not have to get “hot”). On top of that, the sVDEV will significantly speed up processing of small files, an Achilles heel for HDDs.
The main benefit of a L2ARC is that it can fail without the pool being negatively affected. In systems that do some reads also, a default L2ARC can help by keeping some of those files at the ready. I don’t see the use case in a receiving remote machine for that but I have also not used a machine that way either.
The main downside of sVDEV vs. L2ARC is cost and drive bays. You need 3x more drives for the sVDEV than a L2ARC unless you like to live dangerously. Plus, try to plan out the sVDEV and the recordsizes in advance to maximize benefit.