SCHEDULES

SCHEDULE 6 Tax treatment of receipts by way of reverse premium

Application of this Schedule

1

1

This Schedule applies where—

a

a person receives a payment or other benefit by way of inducement in connection with a transaction being entered into by him or a person connected with him;

b

that transaction (the “relevant transaction”) is one under which the person receiving the payment or other benefit, or as the case may be the person connected with him, becomes entitled to an estate or interest in, or a right in or over, land; and

c

the payment or other benefit is paid or provided by—

i

the person (“the grantor”) by whom that estate, interest or right is granted or was granted at an earlier time, or

ii

a person connected with the grantor, or

iii

a nominee of, or a person acting on the directions of, the grantor or a person connected with the grantor.

2

The payment or other benefit is referred to in this Schedule as a “reverse premium”.