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HMRC internal manual

Venture Capital Schemes Manual

From
HM Revenue & Customs
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EIS: income tax relief: withdrawal or reduction of EIS relief: call and put options

ITA07/S211, S212

Income tax relief is not available in relation to any shares if at any time before the termination date there is a put option or a call option over the shares.

A put option is defined by the legislation as an option granted to the investor by any person which, if exercised, would bind the grantor to purchase any of the relevant shares.

A call option is defined as an option granted by the investor which, if exercised, would bind the investor to sell any of the relevant shares.

Similarly, deferral relief is not available in relation to any shares where there is either a put option or a call option over the shares (see VCM23280).