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Contents

Official guidance
Capital Gains Manual

CG55400P · Shares and securities: quoted options to subscribe for shares, traded and financial options

  • CG55400 · Quoted options to subscribe for shares, traded and financial options: introduction
  • CG55402 · Quoted options to subscribe for shares, traded and financial options: income or CG
  • CG55415 · Quoted options to subscribe for shares, traded and financial options: losses
  • CG55416 · Quoted options to subscribe for shares, traded and financial options: not wasting assets
  • CG55431 · Quoted options to subscribe for shares: definition
  • CG55433 · Quoted options to subscribe for shares: acquisition cost: detachable warrants
  • CG55445 · Quoted options to subscribe for shares: position of purchaser
  • CG55455 · Quoted options to subscribe for shares: treatment of company: grant of option
  • CG55456 · Quoted options to subscribe for shares: treatment of company: detachable warrants
  • CG55458 · Quoted options to subscribe for shares: position of company if warrants are exercised
  • CG55465 · Quoted options to subscribe for shares: issue of warrants by person other than co: overseas bank
  • CG55477 · Quoted options to subscribe for shares: bonus issue of share warrants
  • CG55485 · Quoted options to subscribe for shares: issue with share reorganisation
  • CG55490 · Quoted options to subscribe for shares: issue with share reorganisation: example
  • CG55512 · Traded options: definition
  • CG55513 · Traded options: LIFFE
  • CG55514 · Traded options: LIFFE: standard form
  • CG55518 · Traded options: LIFFE: standard form: American style and European style contracts
  • CG55520 · Traded options: LIFFE: standard form: premium paid
  • CG55523 · Traded options: LIFFE: Grant of option: premium received
  • CG55525 · Traded options: LIFFE: purchaser of option: closing sales
  • CG55526 · Traded options: LIFFE: purchaser of option: exercise of option
  • CG55528 · Traded options: LIFFE: writer of option: closing out
  • CG55535 · Traded options: tax treatment: a series
  • CG55536 · Traded options: tax treatment: summary
  • CG55545 · Traded options: tax treatment: grantor of option: option closed out
  • CG55566 · Financial options: definition
  • CG55570 · Financial options: min-max contracts
  • CG55571 · Financial options: over-the-counter options
  • CG55580 · Financial options: Stock exchange traditional options
  • CG55582 · Financial options: Stock exchange traditional options: traded options
  • CG55590 · Financial options: tax treatment of grantor
  • CG55600 · Financial options: tax treatment of grantee
  1. Shares and securities: quoted options to subscribe for shares, traded and financial options: contents
  2. Quoted options to subscribe for shares: treatment of company: detachable warrants

CG55456 | Quoted options to subscribe for shares: treatment of company: detachable warrants

From HM Revenue & Customs · Capital Gains Manual

Quoted options to subscribe for shares often take the form of a share warrant attached to an issue of bonds or debentures. The share warrants may be offered as an inducement to purchase the bonds or to achieve a mixture of debt and equity funding. It will be necessary to apportion the sums received by the company between the amount attributable to the bonds and the amount attributable to the warrants. This should be done on a just and reasonable basis, TCGA92/S52 (4).

Usually you will be able to accept the figures given in the prospectus or offering circular, see CG55434. If no apportionment is offered or the allocation appears unreasonable you should make the just and reasonable apportionment by reference to the respective market values of the bonds and warrants on the first day they are quoted separately.

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