Relief is available where a financial institution purchases a
property and leases it to an individual over an agreed term and at
the end of that term transfers the reversion to that individual.
As three land transactions take place under these
arrangements the effect of the relief is to bring the stamp duty
land tax payable on the purchase of a property using these
arrangements in line with the tax that would be due where a
purchase is made using a conventional mortgage product.
The parity is achieved by relieving the second (lease) and
third (eventual transfer of reversion) transactions from stamp duty
land tax and disapplying the substantial performance tests in
FA03/S44 and options rules in FA03/S46.
