Since the 6th of April 2020, individuals whose earnings are over £240,000 have been affected by the annual taper allowance for pension contributions. In its basic format, your allowance for obtaining tax relief on pension contribution is reduced by £1 for every £2 your taxable income is over £240,000.
The maximum reduction is £36,000, so this means that if your income is over £312,000, then the amount of pension contributions you will receive tax relief on will be limited to £4,000. Any contributions over this amount will be subject to a Pension Savings Tax Charge.
This can cause an issue, especially if you are a pension scheme member whose annual contributions are over your reduced allowance. The consequence is that each year you will have to pay pension tax on the balance over the reduced annual allowance. It could result in a tax charge even though your total pension annual pension contribution is less than the standard annual allowance.
The charge could be incurred if you exceed your annual allowance, plus any carry-forward amounts, the MPAA or both. Who pays the contributions is irrelevant as it is a tax on the individual.
How much Pension Savings Tax will I pay?
The pensions savings tax charge will be assessed using your self-assessment tax return each year. It will be charged at the marginal tax rate and will take into consideration your taxable income and your pension savings.
An alternative way of paying the tax could be via your pension scheme. Some schemes have an option called Voluntary Scheme Pays (VSP) Rules. Not all pension providers will offer Voluntary Scheme Pays as it is optional. However, an increasing number are doing so.
What's Voluntary Scheme Pays?
Voluntary Scheme Pays rules allow individuals to pay pension savings tax charges each year from their pension plan. The pension scheme will pay the annual charge to HMRC directly on your behalf. The tax charge will be taken from your pension savings or accrued benefits. The pension provider will usually pay the tax charge before the 31st of January, following the end of the tax year. The advantage of using this way to pay the tax is that it does not trigger any benefit crystallisation event. This can be especially useful if your pension fund is close to the pension lifetime allowance.
As financial advisors, we offer this as part of our service to our clients.
Who calculates the tax for Voluntary scheme payments?
You would be responsible for this (with the help of either your accountant or Independent Financial Planner if you have one). As a member, you can inform your provider or Scheme about the amount of pension savings tax you are required to pay. You can do this by using a “scheme pays notice”. They will then send you a form to complete, and you will then return it to the provider. The amount of pension tax can then be paid by the product provider.
When is the deadline to submit for Voluntary Scheme pays?
As each provider is different, it is worth finding out as soon after the end of the tax year as possible.
Financial Planning and the Lifetime Allowance
If your pension fund is over or close to the Lifetime allowance for pension purposes, the Voluntary Scheme pays rules could help with financial planning.
What does this mean for members' benefits?
A pension scheme that pays part or all the tax charges must also reduce their benefits. Otherwise, members could be subject to unauthorised payments charges. A money purchase arrangement reduces the member’s funds by the amount charged (including any early withdrawal fees, if applicable). There are many options for how a plan reduces the member’s accrued benefits. However, any adjustment must be ‘just and reasonable’ in defined benefits arrangements. An annual allowance fee cannot be charged on dependents’ pensions, death benefits, or contract-out rights like guaranteed minimum pensions.
How we can help the Voluntary Scheme pays arrangements
Consilium Asset Management are used to dealing with pension scheme providers that offer the VSP options.
The HMRC scheme to pay guidance can be found here: