Phil Ainsley, Managing Director, Employees Services, comments: “Everyone understands the importance of registering their share plans, but with so much else going on, including reviewing plan rules, registration may still be outstanding. I am concerned that by leaving things to the last minute, some companies may not allow themselves a margin of time to act and so jeopardise the tax advantaged status of their plans. In the countdown to the deadlines, our employee share plans relationship team are there to provide any support that is needed as registering your share plans as soon as possible is now key.”
Self-certification
Registration involves companies certifying that their tax advantaged share plans are being operated in line with legislation. One issue that has emerged recently relates to notifying employees of any restrictions attached to shares. It looks likely that this includes any Model Code restrictions for PDMRs. This may mean updating plan documentation (possibly terms and conditions) with some appropriate wording about dealing restrictions and we will keep you informed as to progress with this.
Online filing
From April 2015 Equiniti will be providing annual return data in a new format. This is to enable our clients to file their returns through the HMRC portal (access is via the ‘View schemes and arrangements’ page in the ERS section). At the end of February, following a period of feedback and review, HMRC provided updated ‘technical notes’ which detail how to create the new files. We have a new set of reports under development and these should be tested and ready to use in April.
Discussions with HMRC have been useful and have clarified not only the formats and what additional information is required for the 2014/15 returns, but also the process around making adjustments to previous returns where there has been a delay in reporting leavers. From 2014/15 SIP ‘late’ leavers will need to be included on the relevant online return with the whole return requiring refiling. Recording leavers prior to this period will require the filing of a ‘paper’ schedule (Form 39 format) with a letter explaining why there is late reporting. Phil Ainsley adds:
It’s great that we are now able to progress with IT development so we can support clients with their ERS filing requirements. It’s taken a while to gather and understand all the requirements from HMRC, but the end result will mean progress with a more automated process and removal of paper.
Templates of the new annual return spreadsheets have been added to the .gov site. In addition, HMRC Bulletin 18 provides information about how you can preview the end of year filing process using some example scenarios.
For more information, please contact your relationship manager.
E-Zine issue: April 2015