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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 4 Company Share Option Plan (CSOP): Exchange of share options: Income tax consequences

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

Paragraph 27(5) provides that for the purposes of the CSOP code the new options are regarded as having been granted when the old options were granted.