If you are operating a non tax-advantaged share scheme or making awards of non tax-advantaged shares or securities (an Unapproved Plan), you may already be aware that the deadline to register your arrangement with HMRC is 6 July 2015. Here’s our short guide on why and how to register.
Why must I register my Unapproved Plan with HMRC?
HMRC is attempting to simplify compliance administration by moving from paper to online filing. To facilitate this, UK tax legislation now requires registration of share plans online.
If you do not register your existing Unapproved Plan with HMRC then you will not be able to comply with new statutory requirements requiring you to submit annual returns online for the tax year 2014/15 onwards.
How to register your Unapproved Plan with HMRC
We are unable to register the Unapproved Plan on your behalf; this is something that the Company must do.
What needs to be reported to HMRC?
Form 42 reportable events cover most activity relating to employee shares and securities including, but not limited to, the following:
How to complete annual reporting requirements online
If an annual return is not received by 6 July 2015, automatic penalties will apply.
We would advise that you register your existing Unapproved Plan(s) well before 6 July 2015 because we have found that registration takes longer than anticipated and as with anything new, there is a learning curve for all involved.
Please note that online registration with HMRC applies to other employment related securities, not just Unapproved Plans. For example, HMRC will also expect you to register any existing EMI Plans, Share Incentive Plans, Company Share Option Plans and other employment related securities with HMRC in advance of the 6 July 2015 deadline.
This publication is intended for general guidance and represents our understanding of the relevant law and practice as at May 2015. Specific advice should be sought for specific cases; we cannot be held responsible for any action (or decision not to take action) made in reliance upon the content of this publication.
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