2(1)A reverse premium shall be regarded for the purposes of the Tax Acts as a receipt of a revenue nature.
(2)Where the relevant transaction is entered into—
(a)by the person receiving the reverse premium, and
(b)for the purposes of a trade, profession or vocation carried on or to be carried on by that person,
the reverse premium shall be taken into account in computing the profits of that trade, profession or vocation under Case I or II of Schedule D.
(3)If sub-paragraph (2) does not apply, the person receiving the reverse premium is chargeable to tax as if it were a receipt of a transaction entered into by him for the exploitation, as a source of rents or other receipts, of an estate, interest or right in or over the land in question.