Commentary

D8.356 Put and call options

Corporate tax
Corporate tax | Commentary

D8.356 Put and call options

Corporate tax | Commentary

D8.356 Put and call options

Investment relief attributable to relevant shares is withdrawn if, during the qualification period, either:

  1.  

    (a)     a put option (binding the grantor to buy shares) is granted by a third party; or

  2.  

    (b)     a call option (binding the grantor to sell shares) is granted by the investing company

in respect of those shares1.

The shares to which the option relates are those that would be treated as disposed of if the option were exercised in relevant circumstances. Those circumstances are that the option was exercised when granted and any shares that the investing company acquired in the

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