472Introduction to taxation of share options
(1)The starting-point is that liability to tax may arise by virtue of Chapter 1 of Part 3 (earnings) or Chapter 10 of that Part (taxable benefits: residual liability to charge) when the share option is received, but not when it is exercised.
(2)But section 474 (no charge in respect of receipt of shorter-term option) contains an exemption from this liability.
(3)Liability to tax may arise when the share option is exercised by virtue of—
(a)Chapter 8 of Part 3 (taxable benefits: notional loans in respect of acquisitions of shares), or
(b)section 476 or 477 (charge on exercise etc. of option).
(4)Liability to tax may also arise when the share option is assigned or released by virtue of section 476 or 477.
(5)There are special rules relating to share options received under—
(a)approved SAYE option schemes (see Chapter 7 of this Part),
(b)approved CSOP schemes (see Chapter 8 of this Part), or
(c)enterprise management incentives (see Chapter 9 of this Part).