This is a reminder that the UK deadline for filing annual returns for tax advantaged and non-tax advantaged (formerly unapproved) employee share plans for the tax year 2014-15 is 6 July 2015. HM Revenue & Customs (HMRC) should have already sent you a Notice to File but if they have not then there is still an obligation to notify HMRC of any reportable events.
This deadline applies to Save As You Earn share option plans, Share Incentive Plans, Company Share Option Plans, Enterprise Management Incentives arrangements, non-tax advantaged share and share option plans and also (with limited exceptions) any other acquisition of shares or interests in shares by employees or directors (for example shares issued under the employee shareholder status arrangement).
In addition, any Save As You Earn, Share Incentive Plan and Company Share Option Plan that has previously received formal approval from HMRC will need to be registered with HMRC before 6 July 2015. Failure to register these existing approved plans by that date will trigger loss of their tax-advantaged status.
In contrast to previous years, completed annual returns must be submitted using HMRC Online Services from where there is access to the Employment Related Securities (ERS) service. It is necessary to first register the relevant scheme using the online ERS service, before the annual return for that scheme can be submitted.
If you have reportable events during the 2014-15 tax year which are not related to any particular scheme (for example, because you have made a one-off grant of a share option to an employee or director), HMRC's advice is that you should register another "scheme" for the purposes of reporting that one-off event. This "scheme" can then be used as a catch-all for reportable events which are not already captured under any formal scheme you may have established.
If you do not have an account for HMRC Online Services you will need to register with the Government Gateway, instructions for which can be found here.
The relevant templates for the various annual returns (together with guidance notes) can be found here.
Should the forms be completed inaccurately, not returned to HMRC at all or filed after the deadline, HMRC may impose penalties.
If you have not received a Notice to File and you are concerned that you should be notifying HMRC of reportable events in the 2014-15 tax year, or if you require help completing a relevant return, then please contact Graeme Nuttall OBE or Mark Gearing for assistance.
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