25   Equitable owner

(1)  The owner of any equitable estate or interest in land is liable in respect of land tax as if he or she were the legal owner of the estate or interest and land tax is to be assessed accordingly.

(2)  For that purpose:

(a)  the owner of the legal estate is taken to be the primary taxpayer and the owner of the equitable estate is taken to be the secondary taxpayer, and

(b)  there is to be deducted from the land tax payable by the secondary taxpayer in respect of the land such amount (if any) as is necessary to prevent double taxation.

(3)  This section does not apply in respect of land that is subject to a special trust.

(4)  This section is subject to the other provisions of this Act, in particular sections 25A and 26.