It has always been possible (subject, historically, to HMRC approval of the specific scheme rules) to include in the scheme rules the opportunity to exercise options on (or for up to six months after) the various ‘change of control’ events referred to in ITEPA 2003, Sch. 4, para. 26, notwithstanding such change of control (and associated option exercise) might occur within three years from option grant.

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