s 101 Tax treatment of reverse premiums
(1) A reverse premium is treated for income tax purposes as a receipt of a revenue nature. (2) If the recipient enters into the property transaction for the purposes of a trade carried on (or to be carried on) by the recipient, the reverse premium is brought into account in calculating the profits of the trade. (3) If subsection (2) does not apply, the reverse premium is charged to income tax in accordance with section 311 (reverse premium taxed as property business receipt).