By JD Ghosh, Tax Lawyer, Winslows
Annual returns are required to be submitted by all UK businesses operating employee share plans or providing equity-based incentives to employees. This includes tax-advantaged share plans such as EMI, CSOP, SAYE and SIP as well as any non-tax advantaged plans or arrangements such as unapproved options, conditional share awards (or restricted stock units), growth share plans etc.
The deadline for submission of the annual returns is 6 July 2024, for the tax year 2023-24. Separate returns are needed for each share plan registered with HMRC. HMRC will not send any reminders. Late filing will result in penalties.
The returns will need to be filed by using the plan’s unique reference number. The submission of annual returns can either be carried out by the company directly or by an agent appointed by the company to act on its behalf. Please take screenshots of every stage of your annual reporting, for your records as HMRC will not send any acknowledgements.
Each return must cover all reportable events in relation to each employee share plan that have taken place in the last tax year, including:
- the grant, exercise, cancellation, lapse or release of options;
- the grant, vesting, assignment or release of other share awards like conditional share awards or restricted stock units;
- the grant of SIP awards and SIP shares ceasing to be subject to the SIP;
- post-acquisition chargeable events in relation to restricted securities;
- post-acquisition benefits received in relation to convertible securities;
- other post-acquisition benefits received in relation to employment-related securities;
- discharges of notional loans;
- artificial enhancements of market value of employment-related securities;
- employment-related securities sold for more than market value.
If no ‘reportable event’ has occurred in the last year, a ‘nil return’ is still required to be filed.
Contact Winslows for further details and support Email info@winslows.co.uk


