8Where the benefit of the consideration for the grant of an interest in, right over or licence to occupy land accrues to a person but that person is not the person making the grant—
(a)the person to whom the benefit accrues shall for the purposes of this Act be treated as the person making the grant; and
(b)to the extent that any input tax of the person actually making the grant is attributable to the grant it shall be treated as input tax of the person to whom the benefit accrues.