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Legislation
Corporation Tax Act 2009

Crossheading Issuers of securities with embedded derivatives: deemed options

  • Section 652 Introduction to sections 653 to 655
  • Section 653 Shares issued or transferred as a result of exercise of deemed option
  • Section 654 Payment instead of disposal on exercise of deemed option
  • Section 655 Ceasing to be party to debtor relationship when deemed option not exercised
  1. Issuers of securities with embedded derivatives: deemed options
  2. Shares issued or transferred as a result of exercise of deemed option

Section 653 | Shares issued or transferred as a result of exercise of deemed option

From legislation.gov.uk

(1)Subsections (2) and (3) apply if—

(a)the option mentioned in section 652(3) is exercised at any time in the accounting period, and

(b)shares are issued or transferred in fulfilment of the obligations under the option (“the relevant disposal”).

(2)Section 144(2) of TCGA 1992 (exercise of options) applies to the relevant disposal as if the tax-adjusted carrying value of the option at the time the company became a party to the debtor relationship mentioned in section 652(2) were the consideration for the grant of the option.

(3)So far as it would otherwise apply, section 17(1) of TCGA 1992 (deemed market value consideration) does not apply to the relevant disposal.

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