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HMRC internal manual

Corporate Finance Manual

HM Revenue & Customs
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Derivative contracts: exclusions from regime: equity derivatives: condition C

Quoted option to subscribe for shares

The third condition, at CTA09/S591(4), is that the derivative is an option to subscribe for shares in a company, and the option is listed on a recognised stock exchange. The company purchasing (or granting) the option must have done so for non-trade purposes or for the purposes of life assurance (or it is a mutual trading company). The provisions of TCGA92/S144 continue to apply to such options.