Plans to tackle pensions tax relief for high earners could be 'impracticable'

23 June 2010

Government proposals to restrict pensions tax relief for high-earners could be “complex and impracticable” to implement, according to an assessment of George Osborne’s first Budget by law firm Pinsent Masons.

Simon Tyler, Legal Director in the Pensions Group at Pinsent Masons, says: “We welcome the Coalition’s stated intention to ensure its proposals are ‘fair, simple and sustainable in the long-term’.

“However, it’s not going to be easy overcoming the technical difficulties the government has itself identified. If the measures were totally fair, they would have to be complex and impracticable. The challenge is to find a balanced approach.”

In yesterday’s Budget the Chancellor announced that the government is considering adopting a new approach to restricting tax relief for high earners. Instead of the complex proposals put forward by the Labour government, the coalition government intends to use the existing system of allowances (particularly the annual allowance) to raise the same level of revenue as had already been accounted for. 

The new annual allowance is likely to be in the region of £30,000-£45,000. The current "anti-forestalling" provisions (which are designed to prevent individuals from increasing their current pension savings now to avoid the future tax restrictions) will remain in place in the meantime.

The government intends to address the following technical difficulties, which had already posed problems for Labour's original proposals:

  • How pension accrual in DB schemes would be measured.
  • Ensuring basic-rate taxpayers are not subject to the restriction, and countering hardship caused by sudden increases in pension accrual.
  • Flexibility for individuals in paying any tax charge.
  • Practical aspects of compliance and delivery.

Government plans to consult on removing the effective obligation to purchase an annuity by age 75 in 2011 were also announced. Transitional provisions will apply to those who reach age 75 in the meantime.

Tyler says: “This is a radical step. The details may prove more complex than anticipated - unless the coalition is happy for individuals to contribute to pension schemes to avoid inheritance tax rather than to save for retirement.”

The government also revealed that its proposed measures to tackle arrangements seeking to avoid, defer or reduce income tax and National Insurance Contributions will extend to unregistered pension schemes (known as Employer Financed Retirement Benefit Schemes).  Legislation will be introduced to take effect from April 2011.

For further information please contact:

Paul Beadle
Brazil, Pinsent Masons PR Agency

Mbl +44 (0)7801 105001

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