Annual Allowance

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20/01/2012

Transitional Annual Allowance PIPs ending in 2011/2012

There are different annual allowance rules for Pension Input Periods that commenced before 14 October 2010 but end in the 2011/12 tax year.

A large proportion of PIPs that end in 2011/2012 started before the announcement on 14 October 2010. Individuals may have made significant contributions, greater than £50,000, based on assumption that the annual allowance for 2011/12 would be £255,000.

To offer some form of protection, transitional rules were introduced for pension input periods starting before 14 October 2010 that end in 2011/12 tax year. The transitional rules ensure that an annual allowance charge will not apply to any pension input amount of more than £50,000, subject to a maximum of £255,000, where that saving was built up before 14 October 2010 for pension input periods ending in 2011/12.

Key points to note

  • The transitional rules work by treating the pension input period as if it were two separate input periods. The ‘pre-announcement period’ starts from the beginning of the PIP and ends on the 13 October 2010 and the ‘post announcement period’ starts on 14 October 2010 to the end of the pension input period.
  • The maximum tax relievable pension saving a member can have in one or more arrangements that have a pension input period that straddles the 14 October 2010 but end in the tax year 2011/12 is £255,000, but the maximum pension input that could be made to such a PIP from 14 October 2010 until the end of that pension input period is £50,000.
  • To value the pension input amount under a Defined Benefit scheme the valuation factor is 10:1 for the pre-announcement period and 16:1 for post-announcement period. It is necessary to know the rate of pensionable pay at 13 October 2010 to work out the pension input in respect of the pre- and post-announcement PIPs. In calculating the opening value for both these periods a full CPI increase is given. For PIPs ending in 2011/12 the CPI is that for September 2010 ie 3.1%).

What amount would be subject to an Annual Allowance Charge?

The chargeable amount in respect of the post-announcement period (14 October 2010 till the end of the PIP) is the amount of the pension input that exceeds £50,000 for that period.

The chargeable amount in respect of the pre-announcement period (start of the PIP to

13 October 2010) is the value of the pre announcement period pension input less the difference between £255,000 and the lower of £50,000 and the amount of the post-announcement pension input. If the result is negative the chargeable amount is nil.

Examples

Defined benefit scheme accrual

Emma is a member of the XYZ defined benefit pension scheme. The scheme has a 1/60ths accrual rate and she has 20 years pensionable service. The pension input period for the scheme is from 1 May to 30 April and her pensionable earnings on 1 May 2010 are £40,000, increasing to £42,000 by the 13 October 2010 and £52,000 on 30 April 2011.

Pre-announcement PIP:

Opening value:
20/60 x £40,000 = £13,333.33 x 10 (valuation factor) = £133,333.30 x 1.031 (CPI) = £137,466.63
Closing value:
(20 + 166/365)/60 x £42,000 x 10 = £143,183.56

The increase in the pre-announcement PIP is £143,183.56 - £137,466.63 = £5,716.93

Post-announcement PIP:

Opening value:
(20 + 166/365)/60 x £42,000 x 16 (valuation factor) = £229,093.70 x 1.031 = £236,195.60
Closing value:
21/60 x £52,000 x 16 = £291,200

The increase in the post-announcement PIP is £291,200 - £236,195.60 = £55,004.40

The post-announcement PIP exceeds £50,000, so the amount subject to a charge is £5,004.40 (ignoring any carry forward of unused annual allowance)

The pre-announcement chargeable amount is £0 since (£5,716.93 – (255,000 – 50,000) = - £199,283.07)

Emma’s total chargeable amount for 2011/12 is £5,004.40

Money purchase accrual

Fred contributes to a personal pension arrangement that has a PIP that runs from 1 September 2010 to 31 August 2011. He paid a single contribution of £60,000 on 30 September 2010 and he pays another single contribution on 1 November 2010 for £20,000. His pension savings will not be subject to an annual allowance charge for the 2011/12 PIP as the total pension contribution for 2011/12 PIP is less than £255,000 and he has not paid a contribution of more than £50,000 for the post-announcement period.

This article is based on Skandia’s interpretation of the law and HM Revenue & Customs practice as at January 2012. We believe this interpretation to be correct, but cannot guarantee it. Tax relief and the tax treatment of investment funds may change.

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