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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
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Quoted options to subscribe for shares: position of company if warrants are exercised

If some or all of the quoted options to subscribe for shares issued by a company are exercised TCGA92/S144 (2) treats the grant of the option and the issue of the shares as a single transaction. Any liability on the grant of the option is adjusted accordingly, see CG12317.

The issue of shares by a company is not treated as a disposal and therefore there is no further charge on the company if the option is exercised.

Suppose the company received £200,000 for the grant of the option and £10 million for the issue of the shares. It would be treated as though it had issued the shares for consideration of £10.2 million.