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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Quoted options to subscribe for shares: treatment of company: detachable warrants

Quoted options to subscribe for shares often take the form of a share warrant attached to an issue of bonds or debentures. The share warrants may be offered as an inducement to purchase the bonds or to achieve a mixture of debt and equity funding. It will be necessary to apportion the sums received by the company between the amount attributable to the bonds and the amount attributable to the warrants. This should be done on a just and reasonable basis, TCGA92/S52 (4).

Usually you will be able to accept the figures given in the prospectus or offering circular, see CG55434. If no apportionment is offered or the allocation appears unreasonable you should make the just and reasonable apportionment by reference to the respective market values of the bonds and warrants on the first day they are quoted separately.