Jurisdiction(s):
United Kingdom

Company Share Option Plans during corporate events: UK tax relief, flotations, PISCES, share capital adjustments, demergers and option exchanges on change of control

Published by a LexisNexis Share Incentives expert

Practice notes

Specific issues can arise for CSOP options when the relevant company experiences a corporate event, including how that event affects outstanding CSOP options and whether the company may grant further CSOP options at or after that time. In most cases, the CSOP legislation and HMRC guidance—together with the particular provisions of the plan rules and grant documents—will be highly pertinent to the actions available to the company in these circumstances.

This Practice Note addresses:

tax relief for the exercise of CSOP options on specified corporate events
CSOPs and flotations
CSOPs and Private Intermittent Securities and Capital Exchange System (PISCES) trading events
adjustments to CSOP options on bonus / rights issues and other variations of share capital
CSOPs and demergers, and
exchange of CSOP options on a change of control

Tax relief for the exercise of CSOP options on specified corporate events

When a company undergoes a corporate event, a central point for any pre-existing CSOP options is to assess whether CSOP tax relief can be preserved for them. The legislation that governs the tax treatment of the exercise...

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Web page updated on 21/05/2026

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