As trailed in our previous post, HMRC has just published the FAQs about its new online service for share plans.

It’s clear that it’s very much do-it-yourself.  If you want confirmation that your registration of a share plan or notification of an EMI option grant was successful, make sure you print and save a copy of the final screen, since this is the only acknowledgement you’ll get.  The Revenue will no longer provide you with that handy list of EMI option grants every time you notify, like they used to.  And once an EMI grant notification has been successfully submitted, you can’t view the contents again should you wish.

Also, you need to get it right.  If you make a mistake in registering a plan or notifying an EMI grant, it can’t be corrected once you submit online.

If you register a plan and get its name or type wrong, you’ll have to re-register it with its correct name or type under a separate reference number.  You can then cancel the registration of the incorrectly-named or -typed plan using the “ceased schemes” route, but you’ll still have to submit a nil annual return for it.

If you make a mistake in notifying an EMI option, you will have to make another notification for the same option with the correct details and then report the cancellation of the original (incorrect) option in the annual return for that year.  So make sure you keep a careful note of how many EMI options you really have outstanding!

However, there are some useful titbits:

  • the name of the plan you use for registering should, for tax-advantaged plans, be the full name of the plan, but for non-tax-advantaged plans it should merely include the name of the company;
  • if you aren’t currently using a non-tax-advantaged plan, there is no requirement to register it.  You only need to do this for a tax year in when there is a reportable event, such as a grant of new awards;
  • a company can choose to register all its non-tax-advantaged plans under one reference number – after all, these are all the same to the Revenue and one kind of annual return fits all (the old paper form 42 for the 2013/2104 tax year and its online equivalent for subsequent years).  Each tax-advantaged plan has to be registered separately though; and
  • you can register a plan under any active or live PAYE number, so if the holding company doesn’t have any employees and therefore no PAYE number, you can use that of any subsidiary in the group.