If the employee is merely in the position of being able, by virtue of his employment, to accept an offer to allot shares to him on preferential terms, no taxable earnings arise until such time as he accepts the offer. ITEPA 2003, ss 471–484 (Pt 7, Ch 5), which imposes a tax charge on the exercise of a share option (and normally removes any charge which would otherwise arise on the grant of the option, see E4.508J), has no application in circumstances such
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