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HMRC internal manual

Venture Capital Schemes Manual

HM Revenue & Customs
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VCM: EIS: deferral relief: shares issued on or after 6 April 1998: put and call options


Where an investor subscribes for eligible shares and during the relevant period, see VCM23290, either:

  1. the investor is granted a put option (being an option binding the grantor to acquire the investor’s shares on particular terms), or
  2. the investor grants a call option (being an option binding the investor to dispose of his shares to the grantee on particular terms),

over any of those shares, the shares to which the option relates shall be treated as:

  • never having been eligible shares if the option is granted on or before the date of issue of the shares, or
  • ceasing to be eligible shares on the date the option is granted if that date is after the date of issue.

The shares to which the option relates are those shares which will be treated as being disposed of when exercising the option assuming:

  1. the option were exercised immediately after being granted, and
  2. any shares acquired by the investor in the company after the grant were disposed of immediately after being acquired.