Annual share plan returns must be filed with the UK tax authorities (Her Majesty's Revenue & Customs or HMRC) in relation to equity awards in the UK on or before 6 July following the end of each UK tax year, which runs from 5 April to 6 April. The returns for this year will not be staggered and companies are encouraged to submit their returns as early as possible.

The annual share plan return must be filed online with HMRC on or before July 6 by the local entity using its unique reference/ identifier number. The template forms for the returns and guidance on how to complete the forms can be found here. We are happy to report there have been no changes from last year for both the non-tax advantaged plans (described as Other plans by HMRC) and the tax advantaged CSOP, SAYE, EMI and SIP plans.

The return must report:

  • the grant, exercise, assignment or release of options or receipt of a benefit in money or money's worth in connection with the options;
  • the grant, vesting, assignment or release of RSUs or receipt of a benefit in money or money's worth in connection with said awards; and
  • the grant of purchase rights and purchase of shares under the ESPP

Prior to submitting the returns (or in connection with submitting the returns), companies can upload the forms and check the files for formatting errors by using the HMRC's checking service.

The reporting of equity awards in connection with corporate transactions and for mobile employees can be complex. If you have any questions, or would like assistance with reporting these items or completing the returns generally, please contact your Global Equity Services attorney.