(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)
We do not distinguish between schemes where benefits have
been secured by regular contributions and those set up at the last
minute. Our main concern is that the benefits should be acceptable
both in form and amount. Where, however, the scheme is set up at
such a late date to benefit controlling directors or their
relatives and large contributions are paid, the possibility of an
objectionable tax avoidance motive cannot be ruled out. The scheme
must therefore be looked at critically.
(This text has been withheld because of exemptions in the
Freedom of Information Act 2000)