Have you registered your share plans online with HMRC?
If you operate an existing share plan (UK tax-advantaged or UK non tax-advantaged), these must be registered
with HMRC. See https://www.gov.uk/tell-hmrc-about-your-employment-related-securities
Why must share plans be registered?
HMRC, in line with other government departments, is attempting to simplify compliance administration i.e. move from paper to online. To facilitate this, UK tax legislation now requires registration of share plans online. This in turn enables two other interlinking legislative requirements – the annual filings process and the former approvals process (now called self – certification) – to be met online too.
- Annual filings. Once a plan is registered, this triggers a unique reference number, which in turn is used to submit annual filings online
- Approvals (now self-certification). Previously tax relief was only available once HMRC had given approval to a SAYE, SIP or CSOP plan. Now, at the point of registering online, the company “self-certifies” that the plan meets the relevant legislative requirements.
When must you register with HMRC?
The deadline for existing plans (both UK non tax-advantaged and UK tax-advantaged) is 6th July 2015.
What happens if you do not register existing plan(s)?
The tax advantages of the plan(s) may be lost (even if already “approved” under the now redundant process).
What else is required at registration stage?
You will need to be registered to use HMRC Online Services - this, on its own, can take up to 7 days to obtain login details.
Why is it advisable to register your existing plan(s) well before 6th July 2015?
As with anything new, there will be a learning curve for all involved. HMRC is quite prescriptive in terms of submission templates and software requirements. Penalties exist for late filing and incorrectly completed/formatted returns. Where relevant, loss of beneficial tax treatment may also occur.
For those of you who account for share based payments using accounting standard IFRS 2, the IASB has proposed some amendments for comment, see http://www.ifrs.org/Alerts/Publication/Pages/IASB-publishes- Exposure-Draft-proposing-amendments-to-IFRS-2-Share-based-Payment-November-2014.aspx. Thankfully, the focus is on clarification of some technical points rather than a radical overhaul.
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