A new online registration and filing regime for share plans came into force on 6 April 2014; the first annual filing deadline under the new regime will be 6 July 2015. Set out below are 5 top tips for companies to ensure a smooth transition to the new regime.
1. Don’t leave it until the last minute
Although 6 July may seem a long time away, you should start the registration process as soon as possible. There are quite a few steps to go through before you are in a position to make the filings, and you should build in time to deal with any technical difficulties.
2. Work out what share plans/arrangements need to be registered
You should register any share plan under which there are existing options or awards outstanding. If employees acquire shares outside of a formal share plan you will still need to register the arrangement and you can register your non-tax advantaged arrangements either separately or as one plan. Even if there is no reportable event in the 2014/15 year, it will be necessary to submit a nil return for each plan registered.
3. Start using the HMRC templates to record your data
HMRC have published template spreadsheets for each type of annual return on which the relevant data must be recorded and then uploaded as part of the filing. There is very little scope for changing the format of the template spreadsheets, so it can save time later down the line if you start using the templates to record your data.
4. Ensure you keep records of all information included in the filing
One of the quirks of the new online filing system is that companies and their agents will have no access to annual return information that has been submitted. Therefore, it is very important that you take screenshots of the relevant pages of the online filing process and keep copies of all data schedules submitted.
5. Ensure your tax advantaged plans are compliant
Although tax advantaged plans (CSOP, SIP and SAYE) will no longer require specific approval from HMRC, companies will need to declare as part of the online registration process that the plan meets the relevant legislative requirements.
HMRC has confirmed that if a plan was previously approved by HMRC before 6th April 2014, it will not raise enquiries into whether the plan satisfies the legislative requirements. However, if you have made any changes to a ‘key feature’ of a tax advantaged plan after that date, you will need to confirm compliance again as part of the next following annual return.
- For further information please see our update ‘HMRC annual share plan returns'
For further information or to discuss any of the issues raised, please contact Jonathan Fletcher Rogers at Abbiss Cadres on (+44) 203 051 5711.
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