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HMRC internal manual

Business Income Manual

From
HM Revenue & Customs
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Specific receipts: reverse premiums: conveyance of a freehold

An inducement to buy a freehold interest is not a reverse premium.

Although a person buying a freehold becomes entitled to an estate or interest in land, the inducement is not a reverse premium because of the requirement for the payment or benefit to be paid by the person by whom the estate, interest or right is granted (or by a connected person or nominee etc). A lease or other lesser interest in land is granted because it is created out of a superior interest in that land which the grantor holds. A freehold, however, is the highest interest in land that may be held. It cannot be granted.