Following on from our earlier blog post predicting that companies might have issues when using the new online service for registering employee share plans with HMRC, it appears that problems are indeed emerging.
Despite the looming deadline of 6 July, we hear anecdotal reports that so far only about 25% of plans have been registered. In addition, HMRC has identified particular issues with:
- companies registering the same plan more than once, perhaps in the mistaken belief that each launch of a plan constitutes a new plan, rather than simply another grant/award under the same plan;
- the same plan being registered numerous times, once for each subsidiary that operates it; and
- companies registering tax-advantaged plans in the wrong category (for example, an SAYE scheme as a CSOP).
Unfortunately, at the moment there is no way to correct an entry made by mistake. A plan that has been registered incorrectly will be on the system and therefore an end-of-year return for that plan will have to be made, in which the plan should be reported as having ceased. In addition to which, of course, you will have to register the plan correctly under a separate number.
The full chapter and verse is set out in a letter sent by HMRC to company secretaries. If you are yet to register your share plans, it’s well worth a read, along with the relevant HMRC webpages.