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HMRC internal manual

Capital Gains Manual

Share and securities: Futures: artificial transactions in futures/options: consequential adjustments

TCGA92/S148B, TCGA92/S148C

The ITTOIA05 income rules, see CG56200, generally apply in respect of disposals of futures and options following the TCGA pattern given by Sections 143 to 144A TCGA92. However, where futures run to delivery or options are exercised, an income charge may arise when there is no corresponding CG disposal. Sections 148B and 148C modify the capital gains computations on a disposal of the asset acquired by reason of the option or future to prevent the same amounts being taken into account for both income and capital gains.

Detailed guidance is at SAIM7100 onwards.

These provisions were repealed with effect for 2013-14 and subsequent years.  See now SAIM2710+ and CG14350 for guidance on disguised interest.