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Contents

Official guidance
Capital Gains Manual

CG12300P · Introduction and computation: chargeable assets: options

  • CG12301 · Options: put option or call option
  • CG12310 · Options: taxation
  • CG12311 · Options: taxation: option to enter into non-sale transaction and options to both buy and sell
  • CG12312 · Options: grant of an option
  • CG12313 · Options: exercise of an option: grantor of the option
  • CG12314 · Options: exercise of an option: person exercising the option
  • CG12315 · Options: exercise of an option: indexation allowance
  • CG12317 · Options: exercise of an option: consequential adjustments
  • CG12320 · Options: cash-settled options
  • CG12321 · Options: cash-settled options: treatment of grantor
  • CG12322 · Options: cash-settled options: treatment of person exercising the option
  • CG12330 · Options: wasting assets: disposals
  • CG12340 · Options: abandonment of an option
  • CG12350 · Options: example: call option
  • CG12351 · Options: example: put option
  • CG12360 · Options: abandonment: assets to be used for trade purposes
  • CG12370 · Options: only or main residence
  • CG12380 · Options: option granted to connected person: loss on disposal
  • CG12390 · Options: forfeited deposit of purchase money
  • CG12395 · Options: market value rule
  • CG12396 · Options: market value rule: Mansworth v Jelley: options exercised before 10 April 2003
  • CG12397 · Options: market value rule: effect of TCGA92/144ZA: options exercised on or after 10 April 2003
  • CG12398 · Options: market value rule: examples: employment-related share options
  • CG12399 · Options: market value rule: examples: options other than employment-related share options
  1. Introduction and computation: chargeable assets: options: contents
  2. Options: taxation: option to enter into non-sale transaction and options to both buy and sell

CG12311 | Options: taxation: option to enter into non-sale transaction and options to both buy and sell

From HM Revenue & Customs · Capital Gains Manual

TCGA92/S144 (6) and TCGA92/S144 (5)

Section 144(6) provides that

references to an option include references to an option binding the grantor

  • to grant a lease for a premium, or

  • to enter into any other transaction which is not a sale,

as well as transactions of purchase and sale, references in section 144 to buying and selling in pursuance of an option being construed accordingly.

And Section 144(5) provides that

where the option binds a grantor both to buy and to sell, the option is to be treated for the purposes of section 144 as if it were two separate options with half the consideration attributed to each.

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