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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Computation: date of disposal: options

An option is not in itself a conditional contract but operates as an offer which is irrevocable during the option period. See CG12300+. The grant of an option, made either for good consideration or by deed, gives rise to a binding contract to keep the offer open.

Where in the normal way the option agreement is unconditional, the date of the disposal of the option is given by TCGA92/S28 (1) as the date of that agreement.

Where an option to buy is exercised, the offer is thereby accepted so that a separate unconditional contract is made in relation to the asset which is the subject of the offer. The date of the disposal of that asset is given by Section 28(1) as the date of exercise of the option.