New online filing system: rapid action required by any company with an employee share scheme

HMRC online filing and notification

As we have reported previously, HMRC is introducing an online registration and notification system for employee share schemes. By way of reminder, the key points are as follows.

  • These requirements apply to all kinds of share scheme, including EMI options, CSOP options, unapproved options, share incentive plans (SIPs), SAYE options and all other forms of employee share scheme.
  • All annual returns for tax years ending 5 April 2015 onwards for employee share schemes (whether tax-advantaged or not) must be filed online by 6 July following the end of the relevant tax year.
  • All tax-advantaged employee share schemes must be registered online with HMRC by 6 July 2015 at the latest if their tax advantages are to be preserved.

The steps you need to follow

If you are a company with any kind of share scheme,  you must complete the following steps by 6 July 2015. 

This applies to both tax-advantaged share scheme (EMI, CSOP, Share Incentive Plan (SIP) or SAYE options) and all other forms of employee share or option scheme (including unapproved options, growth or hurdle shares, shares purchased of gifted, restricted shares):

First step:  If not already done so, you must register your company with HMRC’s PAYE online service.  If you haven’t first done this, you won’t then be able to register your share scheme, so the PAYE online registration is the first step.

Second step: Using the online share scheme registration service, you must then register your share scheme by providing your corporation tax reference, company registration number and the type of scheme to HMRC.

Third step: HMRC should then send confirmation of registration and a plan reference number for your scheme by post.   It will go to your company’s registered office so make sure someone there looks out for it.

Fourth step: Complete your share scheme annual return online.  Clearly, there is likely to be a time delay between the second and third steps. Companies which delay registering their share schemes until the last minute could, therefore, miss the deadline for annual returns.

Important Note: A company’s agent cannot register the scheme (second step). Only the company itself can do this.

How to complete and file your share scheme annual return

HMRC has now published revised versions of the annual return filing templates for all tax-advantaged and non-tax-advantaged share schemes for 2014-15. HMRC had first published the templates in February 2015 but quickly removed them after users reported extensive technical problems.
Separate templates are available for the annual returns for:

  • Company share option plans.
  • SAYE option schemes.
  • Share incentive plans.
  • Enterprise management incentives options.
  • All non-tax-advantaged options and awards.

The templates can be found by clicking on the following link.

Registering grants of EMI options

Grants of EMI options after 5 April 2014 must be notified online to HMRC within 92 days following grant if the related tax advantages are to be preserved.  If not already done, you must first have registered with HMRC your EMI scheme.