Where a company acquires shares as a result of the exercise of an option embedded in a loan relationship to which CTA 2009, ss 645, 646 apply (see D1.886), or as a result of the exercise of a stand-alone option which falls to be dealt with under the provisions of the derivative contracts legislation, measures apply to ensure that there is no double counting of any profits or losses that have been taken into account for tax purposes under the derivative contracts legislation.
Embedded options
In the case of options which are bifurcated from a creditor loan relationship, and to which the provisions of CTA 2009, ss 645, 646 apply, where the rights to acquire shares are to any extent exercised or are otherwise disposed of (ie the security is sold rather than being converted into or exchanged for shares), the following provisions
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