RPSM15104570 - Technical Pages: Special annual allowance: Anti-avoidance rules: General anti-avoidance rule

This guidance only applies for the 2009-10 and 2010-11 tax years.

General anti-avoidance rule for protected input amounts

An arrangement will cease to be an arrangement which creates protected pension input amounts if there is a scheme or arrangement (or schemes or arrangements) which has as its main purpose or one of its main purposes to avoid or reduce liability to the special annual allowance charge, the annual allowance charge or the lifetime allowance charge.

The effect of this is that no pension input amounts will be protected in respect of the individual.

Note - the terms ‘scheme’ or ‘arrangements’ are used here in the sense of avoidance devices rather than pension schemes or pension arrangements. Such a ‘scheme’ or ‘arrangement’ includes any agreement, understanding, transaction or series of transactions (whether or not legally enforceable).