UK employee share plan reporting: Prepare now for 6 July
All employee share plan reporting must be completed by 6 July 2016 using HMRC’s (the UK tax authorities’) online filing service, so now is a good time to make sure you are fully prepared. Here are our top tips on what you need to consider.
1. Consider which group company will make the filing
In order to make the online filings a company must first be registered for HMRC online services. However, any group company can make the filing in respect of all group employees. If there is one group company that is already registered, you can make the filing under the PAYE reference of that company.
2. Determine the reportable events for the 2015/16 year
You should cross-check against your previous filings to see which plans/arrangements were previously included. Remember that if employees acquire shares outside of a formal share plan, you will still need to include those transactions in the filing.
Even if there is no reportable event in the 2014/15 year, it will be necessary to submit a “nil return” for each registered plan.
3. Consider how to register your non-tax advantaged plans
It is possible to register your non-tax advantaged plans either separately or as one plan. Which is the best approach will depend on the nature of your arrangements. A separate return will be required for each registered plan, so registering all plans under one umbrella arrangement can have advantages. However, for companies with a wide variety of different share incentives arrangements and a large number of participants, it may be simpler from an administrative perspective to register the different plans separately.
4. Authorise your administrator/adviser well ahead of time
Although companies need to register plans through HMRC online services themselves, the filings can be carried out by a third party agent. Agent authorisation involves sending access codes through the post and can take some weeks to process, so you should make sure you start on the authorisation process now.
5. Keep records of all information included in the filing
One of the frustrations of the online filing system is that companies and their agents have no access to annual return information once it 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.
6. Ensure your tax advantaged plans remain compliant
If you have made any changes to a ‘key feature’ of a tax advantaged plan (Company Share Option Plan, Share Incentive Plan and Savings Related Share Plan) since your last submission, you will need to confirm compliance again as part of your next annual return.
How can we help?
We can provide advice and assistance in relation to all aspects of the annual reporting requirements. For further information on how we can help please contact our share plan team on +44 203 051 5711, or email us.
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