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HMRC internal manual

Stamp Taxes on Shares Manual

Scope of stamp duty on shares: stamp duty: basics of a charge: grant of an option

A document under which an option is granted or released is chargeable with Stamp Duty on the amount paid for the grant or release. (George Wimpey & Co Ltd v IRC [1975] 2 All ER 45).

But following FA03/S125 Stamp Duty now only applies to an instrument granting or releasing an option in or over stock or marketable securities.