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HMRC internal manual

Employee Tax Advantaged Share Scheme User Manual

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HM Revenue & Customs
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Schedule 3 SAYE option schemes: Exchange of options: Income tax consequences

No income tax charge under Section 476 arises on the release of an option (tax advantaged or non-tax advantaged) in exchange for another option (Section 483 ITEPA).

Paragraph 39(5) provides that for the purposes of the Schedule 3 SAYE code the new options are regarded as having been granted when the old options were granted.