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HMRC internal manual

Capital Gains Manual

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

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.