Capital gains tax – Disposal of assets. Section 144ZA of the Taxation of Chargeable Gains Act 1992, which disapplied the market value rule in s 17(1) of that Act, applied where the grantor of share options had a discretion on exercise of the option to satisfy the option holder's entitlement either by transfer of shares or payment of cash. Consequently, the Upper Tribunal (Tax and Chancery Chamber) dismissed the taxpayer's appeal, having decided that the First-tier Tribunal (Tax Chamber) had correctly decided that s 144ZA applied to the taxpayer's exercise of option shares granted to him under the Goldman Sachs 1999 Stock Incentive Plan, thereby disapplying the market value rule.