Beware the ‘blind spot’ in HMRC’s online records for Employment related securities
24 February 2022
For companies who registered Employment related securities (‘ERS’) schemes online with effect from 2014/15, HMRC now only shows and gives access to the most recent seven tax years from 2015/16 to 2021/22. We explain the key issues to consider below.
Mind the ‘blind spot’
Previously, it was possible for companies to check the status of their filings for 2014/15 for any ERS schemes they registered online with HMRC. This is a useful record for companies to have, particularly on a due diligence exercise where EMI options are being exercised or a company has been advised they bring their historic ERS filings up to date.
However, HMRC recently removed the facility to see if a filing was made or to rectify return for that tax year. This gap in online records may make it impossible to rectify a historic return for 2014/15 or check if an EMI notification was made in that tax year without reverting directly to HMRC.
Hints and tips
Until HMRC provide a more formal response on how to address this gap in electronic records, as way of best practice, we suggest clients continue to bring their historic filings up to date for 2015/16 onwards and take care to maintain internal records of any notifications and filings independently of HMRC’s online system. In relation to the 2014/15 tax year itself, companies may wish to make a voluntary disclosure to HMRC.
How we can help you
As way of reminder, the window for share plan reporting opens on 6 April 2022 to report any share plan activity in the 2021/22 tax year. Companies have until 6 July 2022 to file returns for 21/22 with HMRC. We also assist with getting employers up to date with their historic filings for previous tax years and making disclosures (if required) to HMRC.
If you found this article helpful, read more ERS tips on clockwatching and the countdown to the annual share plan filings deadline. ERS reporting from BDO has an outstanding reputation - read more on Share Plan reporting or contact us.
Share Plan is just one of the reporting deadlines that employers need to be aware of for 2022. Read our guidance on how to ensure you have accurate data ready in time to meet all the reporting deadlines: Employers’ Year End 2022.