Stamp Duties Consolidation Act 1999 section 32

As to sale of an annuity or right not before in existence

Section 32 provides that where an annuity or other right not previously in existence is sold but is secured by a bond or other instrument rather than created by actual grant or conveyance, that instrument is charged with stamp duty as if it were a conveyance on sale.

• Where a new annuity or right is created by actual grant or conveyance, that document is itself a conveyance on sale and is stamped accordingly.
• Where the new annuity or right is not created by grant or conveyance but is merely secured by a bond, warrant of attorney, covenant, contract or other instrument, that instrument is deemed to be a conveyance on sale and bears the same duty.
• If more than one instrument secures the annuity or right, only one of those instruments need be stamped.
• The right in question must be a property right — that is, one capable of being completed by grant or conveyance — and its terms must be set out in a written instrument.