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ETASSUM36170 | Schedule 3 SAYE option schemes: Exchange of options: CGT consequences for the option holder

From HM Revenue & Customs · Employee Tax Advantaged Share Scheme User Manual

For Capital Gains tax purposes a paragraph 39 exchange is not treated as involving a disposal of the old options by the option-holder (Section 237A TCGA 1992). The new rights are treated as being the same asset as the old options.