Taxation of Chargeable Gains Act 1992 Schedule BA1 paragraph 3

Grants of options

Paragraph 3 of Schedule BA1 explains how investors' relief applies when a person grants an option to subscribe for shares that would themselves qualify for investors' relief.

  • When an individual grants an option to another person to subscribe for shares in a qualifying company, the grant of that option can itself be treated as a disposal eligible for investors' relief.
  • The shares that would be acquired on exercise of the option must be shares that would qualify for investors' relief in the hands of the person acquiring them.
  • The relief effectively extends the investors' relief regime beyond straightforward share subscriptions to cover the grant of options over qualifying shares, ensuring consistent tax treatment.
  • This provision was introduced by Finance Act 2019, Schedule 1, paragraph 11, as part of the broader investors' relief framework within the chargeable gains legislation.

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