I am acting for Mr A, who in 2016 (15%) & 2017 (5%) purchased shares in his employer B ltd (subsid of foreign co C, in turn a subsid of foreign co D). Unsure of exact financials, but B Ltd prepares under FRS101, latest accounts at CoHo show BS of £250k, PAT c£650k.
There was no formal share scheme in case, C Ltd said "Mr A, do you want to buy shares in your employer, B Ltd?". Mr A has become aware that he should have declared the MV/price difference on his SATR and paid tax on the benefit. I assume that nothing changes from this respect with it not being a share scheme?
It's too late to amend the SATRs, so I was planning to write to HMRC with the calcs as an unprompted disclosure - is this the correct thing to do?
B ltd isn't my client, but would they have any reporting requirements? I've seen something online re Form 42, but that's when there's a share scheme ...?