Taper relief EMI - Readers' planning points, pitfalls and other correspondence

One of the main advantages of options under the enterprise management incentive scheme is that taper relief starts running from the date the option is granted not the date the option is exercised. It has often been the practice with for example shares acquired under an executive share option scheme (what the Revenue now calls a CSOP) to transfer shares to a spouse to use capital gains tax exemptions efficiently. Does this work with shares acquired under an enterprise management scheme option?

Normally of course inter-spouse transfers are neutral as regards fixing the qualifying holding period for a disposal – the transferee spouse is treated as acquiring the shares when the transferor acquired them. But it appears that this does not apply to the special treatment afforded to shares acquired under enterprise management scheme options. In other words the start of the qualifying holding...