Pension Schemes - Frequently Asked Questions

 

Question on Update no 102 (Prohibition on transactions between tax approved occupational pension schemes and non approved top up schemes)

Q. Paragraph 13 of Update 102 says that transactions between approved and non-approved schemes that took place before the Update was issued will be considered in the light of the Update which would mean that such transactions might not be acceptable. Would this be so even if prior Inland Revenue clearance had been given to a particular transaction?

A. Where the trustees or pensioneer trustee or practitioner acting for an approved scheme, such as a small self-administered scheme, have/has received from the inland revenue in writing either general clearance or specific clearance for a transaction or transactions between an approved and non-approved scheme, then that written agreement will be honoured provided the transaction is not made after the issue of Update 102. This confirmation is given on the understanding that the facts and circumstances upon which the written clearance was given did not change between the time the clearance was given and the time of the actual transaction.

Q. Paragraph 11 of Update 102 says transactions of any description between any tax approved schemes and any non-approved schemes are prohibited. Please expand on this.

A. In the context of Update 102 the following are not prohibited:

  • arrangements for the common use of the same administration and/or actuarial services by the trustees of an approved scheme and a "top up" FURBS (provided the approved scheme does not meet any part of the costs attributable to the FURBS);
  • underwriting arrangements whereby the insurer of unapproved funded death in service benefits treats both schemes as one for underwriting purposes;
  • an arrangement entered into when a member of an approved scheme is found to have benefits in excess of Revenue limits whereby his employer agrees to provide unapproved benefits equal to the excess in consideration of a contribution holiday under or a return of excess assets from the approved scheme;
  • the independent purchase by the trustees of a FURBS of shares in a company in which the trustees of an approved scheme have a majority holding - eg some sort of private equity investment vehicle owned by approved scheme trustees;
  • payment of lump sum death benefits by the trustees of an approved scheme and trustees of an unapproved life assurance scheme into the same children's trust.

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