A reverse premium is chargeable in the first instance only if
the
grantor provides the inducement. The
grantor is the person who is now granting, or who
previously granted, the interest in land that is the subject of the
relevant transaction.
In order to block an obvious avoidance route, however, an
inducement provided by certain other persons is also caught. Those
persons are:
(FA99/SCH6/PARA1 (1)(c) and ITTOIA05/S99 (4)).