Included in this issue: Extension of the PSC Regime delayed?; Deadline for annual tax returns for employment-related securities; Report of Joint Committee on Human Rights published report on Modern Slavery Act and more...

Corporate Transparency

Extension of the PSC Regime delayed?

To ensure compliance with Article 30 of the Fourth Money Laundering Directive, which EU Member States must implement by 26 June 2017, changes and extensions need to be made to the current Persons with Significant Control (PSC) regime. While meeting this implementation date now looks unlikely given that draft regulations are yet to be published, certain steps can still be taken in preparation by those likely to be effected. For more detail, click here.


Deadline for annual tax returns for employment-related securities

Online filing of annual returns for employment-related securities is compulsory. All annual returns for the tax year 2016/17 must be submitted by 6 July 2017. Filing reminders and notices to file will not be issued by HMRC in relation to online filing of share schemes returns.

It is worth noting that this filing requirement applies not only to traditional share schemes (whether or not there has been any activity under those schemes during the tax year) but also to any issue, transfer or disposal of employment-related securities. A nil-return filing must be made where a share scheme has previously been registered with HMRC even where there has been no activity in respect of that share scheme during the tax year 2016/17.

There are now automatic penalties for late or inaccurate filing. There is an automatic £100 penalty for a late return, with additional increasing penalties if the return remains outstanding for more than 3 months. In addition, if the return contains material inaccuracies HMRC can impose penalties of up to £5,000 per return if not corrected by an amended return "without delay".

Business Ethics, Modern Slavery and Corporate Crime

Report of Joint Committee on Human Rights published report on Modern Slavery Act

The House of Commons and House of Lords' Joint Committee on Human Rights has published a report on human rights and business. The report sets out various shortcomings of the Modern Slavery Act 2015 and the related guidance, specifically that the requirements to publish a statement are too weak leading to significant variations in the quality of disclosure.

Also, there is no central list of companies required to report, and no requirement for businesses to upload their statements onto a central database (as with Gender Pay Gap and Payment Practices reporting). The Joint Committee believes that this is a barrier to effective compliance monitoring.

Further, the Joint Committee also recommends that the government bring forward legislative proposals to make reporting on due diligence for all relevant human rights, not just the prohibition of modern slavery, compulsory for large businesses, with a monitoring mechanism and an enforcement procedure.

Data Protection

GDPR - 12 months to go

On 25th May 2018, the General Data Protection Regulation (GDPR) will be in force in the United Kingdom. We have produced the attached Timeline, which sets out an action plan for those affected by GDPR to follow over the course of the next year to ensure their readiness for it. 

Key Contacts

Richard Preston

Richard Preston

Managing Associate, Corporate Finance
London, UK

View profile