1203. Contract providing for conveyance to third party for purposes of charge to stamp duty land tax.

Where a contract1 is entered into under which a chargeable interest2 is to be conveyed3 by one party to the contract ('A') at the direction or request of the other ('B'), to a person ('C') who is not a party to the contract, or either to such a person or to B, then B is not regarded as entering into a land transaction by reason of entering into the contract4. Instead:

  1.  

    (1)     if the contract is substantially performed, B is treated5 as acquiring a chargeable interest, and accordingly as entering into a land transaction, and the effective date of