HMRC have taken on board many of the points made to them about the original proposals. However, some uncertainties remain. In particular, HMRC have introduced a new change to the statutory requirements for CSOPs and SAYE schemes relating to the exercise of an option by the estate of a deceased option holder, which needs to be clarified.
The new regime takes effect from 6 April 2014 and our guidance that companies do not need to amend existing HMRC-approved plans before 6 April (unless new grants are to be made imminently) remains.
Squire Sanders and others will continue to work with HMRC to provide clear guidance to employers on the effect of the new self-certification regime.