1202. Contract for a land transaction; conveyance for purposes of charge to stamp duty land tax.

Where a contract1 for a land transaction2 is entered into under which the contract is to be completed by a conveyance3, a person is not regarded as entering into a land transaction by reason of entering into the contract4, but:


    (1)     if the transaction is completed without previously having been substantially performed5, the contract and the transaction effected on completion are treated as part of a single land transaction, and the effective date of the transaction in this case is the date of completion