This part of GOV.UK is being rebuilt – find out what beta means

HMRC internal manual

Employee Tax Advantaged Share Scheme User Manual

Enterprise Management Incentives (EMI): General requirements: Purpose of granting options

In order for an option to be a qualifying option, it must be granted for genuine commercial reasons, to recruit or retain an employee in a company. An option does not qualify if it is granted as part of a scheme or arrangement the main purpose (or one of the main purposes) of which is to avoid tax, (Paragraph 4).