Greater due diligence is required with consequent higher fees. Seller holds property on constructive trust for buyer. No express declaration of trust otherwise contract will be stampable. Stamp Act 1891. Buyer should avoid being given power of attorney under which it can transfer legal estate on seller's behalf.
Power is likely to be a stampable document.
Option may be executed overseas. Company A then surrenders benefit of option to buyer. The Court of Appeal has recently held that the Revenue, to assess duty, is entitled to be informed of all material circumstances. This includes offshore declarations of trust of equitable interest and so would seem to include options or other documents intended to achieve a similar result. Interest runs from date of execution.