Accountants and valuers file a significant number of extension requests for existing EMI agreements. Until now, shares and asset valuation (SAVs) would grant an extension to filed values for a 60-day period, and an additional period of 30 days if requested, by the end of which a new valuation and submission was required. Beginning last month, HRMC withdrew the 30-day extension and now provides an agreement for the full 90-day period. After the 90-day period has expired, the full resubmission will still be required.

Filing for an extension for these valuations does not preclude challenges to the values submitted (particularly if the share valuation is nil, which HMRC has been increasingly challenging even when shares have no voting rights). EMI agreement letters specify that valuations have not been subject to a detailed review. So, for example, SAVs may revisit an EMI valuation if it is felt that the information provided was misleading or a misrepresentation of the facts.