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Since 6th April 2006 (A day) a company has theoretically been able to pay up to £215,000 into each employee’s pension fund and attract full Corporation Tax relief regardless of the Salary of the employee. Unfortunately, the problem was that HMRC then gave each individual local tax inspector discretion over whether or not the large contribution would be allowable for Corporation Tax relief. In our dealings on behalf on quite a few clients, the local inspectors have rarely been willing to give any prior guidance to the large contribution, creating a situation of great uncertainty.
HMRC have recently confirmed that they are reviewing and issuing updated guidance regarding employer pension contributions which should be issued within the next month or so. We hope that these guidelines will give us clarity, but it is quite likely that the guidelines will be less favourable than the interpretation we can currently work with.
If you are considering a large lump sum pension contribution you may wish to consider bringing this decision forward, although you must be aware that in making the large pension contribution under current rules, unless we can obtain prior approval, there is no guarantee of tax relief being approved. The current rules regarding pension contributions can be found at http://www.maaltd.co.uk/pdf/factfile_pensions_a_day1_contributions.pdf
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