(This archived guidance relates to HMRC discretionary
practice before the 6th April 2006. For current guidance on
Registered Pension Schemes see the Registered Pension Schemes
Manual)
There is no objection to an employer giving his employees
non-relevant or non-approvable benefits. But they must not be
offered through a tax approved scheme: they must be kept entirely
outside its trust deed and rules. A retirement benefits scheme can
only be split into approved and unapproved parts by reference to
classes of employees (section 611(3) ICTA 1988). Approval cannot be
split according to the types of benefit; so segregation of the
non-approvable benefits into a separate fund within the retirement
benefits scheme is not acceptable.