The dutiable value of
a dutiable transaction referred to in section 45 is —
(a) the
sum of —
(i)
the amount paid by way of consideration for the granting
of the call option in respect of the option property; and
(ii)
the amount payable in the event of the call option being
exercised in respect of the option property;
or
(b) the
unencumbered value of the option property at the time when liability for duty
on the transaction arises, if —
(i)
there are no amounts paid or payable under
paragraph (a); or
(ii)
the amounts paid or payable under paragraph (a)
cannot be ascertained when liability for duty on the transaction arises; or
(iii)
the unencumbered value is greater than the sum of the
amounts paid or payable under paragraph (a).