PSI5.1.8 - Contributions by Employers: General
- Contributions Only for Own Employees
-
(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)
[PN5.6]
Where there is only one employer our test of the basic
requirements in
PSI5.1.7a and b is straightforward. But
with centralised schemes the position is more complicated. Each
employer should generally contribute only in respect of its own
employees and in relation to their remuneration from and service
with that employer (see
PSI21.2.14). If the
contributions paid by a particular employer are disproportionately
high, that employer is subsidising the other participating
employers. Such cross-subsidies are contrary to the principle in
section 592(5) that:
"The amount of an employer's contributions which may be deducted
........... Shall not exceed the amount contributed by him under
the scheme in respect of employees in a trade or undertaking in
respect of the profits of which the employer is assessable to tax
........ ."
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