Christopher Stiles
Christopher Stiles is a partner based primarily in Birmingham who helps clients to deal with any contentious or non-contentious legal issues that may arise in relation to their pension plans with the greatest possible ease and efficiency.
Pensions can be a challenging area for employers, with pension plans that ranging from legacy arrangements that are now closed to accrual, but are still a major liability on the balance sheet, to ongoing plans that are used to reward current employees.
Christopher takes a particular interest in innovative and complex projects including asset-backed funding arrangements, liability management exercises and buy-outs.
On the trustee side, Christopher has close ongoing relationships with his trustee clients and helps them through the legal issues they face in running their pension schemes, both the day-to-day problems and larger projects including scheme mergers and wind-ups
Practice Area
Panel
- Contributing Author
Qualified Year
- 2005
Membership
- Association of Pension Lawyers
Qualification
- Qualified as a solicitor in England and Wales
5 Contributions by Christopher Stiles
PRACTICE NOTES
Hedging longevity risk in UK DB pension schemes: legal and practical guide to swap structure, pricing, collateral, credit risk, termination and governance
Pension schemes and their sponsoring employers confront a range of risks linked to their defined benefit pension schemes, a notable one being the cost of improving life expectancy. Alongside traditional ways of hedging scheme risk—such as buy-outs or buy-ins—de-risking options based on a ‘swap’ contract have been used for some time. A ‘swap’ is a broad term for an agreement under which the parties exchange a sequence of cashflows tied to an underlying asset or other variable. For more on buy-outs and buy-ins, see Practice Note: De-risking—pension buy-outs and buy-ins.
What is a longevity swap?
A longevity swap is a means for a pension scheme to hedge the risk that members live longer than anticipated. This is now most commonly arranged via an insurance policy (although the earliest transactions were implemented using a derivative). Under a longevity swap, the scheme trustees make pre-determined regular payments—typically monthly or quarterly—to the swap provider over a fixed period, modelled on the then life expectancy for specified members...
Pensions
PRACTICE NOTES
Transferring to a DB superfund: trustee and employer powers, due diligence, TPR clearance and gateway principles, PPF assessment scenarios, communications, GMP equalisation, timing and transaction steps
Rising cost pressures in running a defined benefit (DB) occupational pension have prompted a sharper focus on reducing financial risk and investment swings tied to these arrangements (often called ‘derisking’). The most complete form of de‑risking is a pension buy‑out, which shifts DB liabilities to an insurer. Yet buy‑outs can be costly, and moving to a DB superfund may offer a more economical route. Broadly, a DB superfund is an authorised vehicle to which DB schemes can transfer for a fee, thereby cutting off the employer’s responsibility to the DB scheme. Typically, the employer covenant is substituted with a capital buffer that the superfund can deploy if funding falls below a set threshold. For further details, see Practice Note: DB consolidation—what are DB superfunds? According to the DWP, the entry cost for a DB superfund is expected to be around 10% less than a buy‑out (reflecting the superfund delivering only 98% security for members, versus 99.5% for buy‑outs). Nonetheless, a DB superfund will not suit every DB scheme, in particular:
those who can afford a buy‑out unaided, whether now or in the foreseeable
Choices ultimately depend on affordability and the degree of member security each route is designed to deliver...
Pensions
PRACTICE NOTES
UK pensions taxation: lawyers' guide to registered and unregistered schemes, covering contributions, allowances (2024 reforms), investment taxation, employer relief, VAT, benefits and death benefits, unauthorised payments, refunds and GMP equalisation.
Broadly speaking, tax applies to UK registered pension schemes in three different areas:
the tax treatment of member and employer contributions, including any repayment of member contributions
the tax treatment of assets held by the scheme, including the investment returns generated by those assets
the tax treatment of benefits paid out by the scheme
Where an individual participates in more than one registered scheme, the contributions paid to—and the benefits received from—each arrangement are combined and considered together when establishing that person’s overall tax liability.
This Practice Note concerns registered private sector pension schemes. Public sector pension schemes are predominantly governed by separate legislation. Their tax position is broadly similar, though not invariably the same, as that which applies to registered private pension schemes...
Pensions
PRACTICE NOTES
UK VAT on Occupational Pension Schemes: Input Tax Recovery Options, DC SIF Exemption, Historic Insurance Treatment, and HMRC Policy Evolution (PPG to 18 June 2025)
THIS PRACTICE NOTE RELATES TO OCCUPATIONAL PENSION SCHEMES
This Practice Note cites decisions of the Court of Justice of the European Union (CJEU). For direction on whether EU judgments bind courts in the UK, see Practice Note: Assimilated law—Assimilated case law.
VAT basics
The United Kingdom’s Value Added Tax (VAT) regime, originating in European law, is principally set out in the Value Added Tax Act 1994. VAT is a levy on consumer spending. A VAT-registered business must account to HMRC for VAT on the value of supplies of goods and services it makes, and therefore adds VAT to the amount it charges its customers for those supplies. That business may obtain credit for VAT it incurs on goods and services it uses. The VAT added to its prices is termed ‘output tax’, while VAT recoverable on its purchases is termed ‘input tax’. VAT only applies to ‘taxable supplies’. Only ‘taxable supplies’ fall within the scope of VAT in the UK itself. Exempt areas include insurance and the provision of finance under VAT rules. Not every supply is taxable—eg insurance and the provision of finance are exempt from VAT. Certain narrowly defined supplies are taxable at the zero rate or at...
Pensions
PRECEDENTS
Conflicts of Interest Policy and Procedures for Trustees of Occupational Pension Schemes
1 Background
1.1 This policy covers the [ trustees (‘the Trustees’) OR directors of [ insert company name ] (‘the Trustees’), acting in its role as corporate trustee ] of the [ insert name of pension scheme ] (‘the Scheme’).
1.2 Each Trustee has an obligation to act even‑handedly and to advance the aims of the Scheme, while considering the interests of the Scheme’s beneficiaries as a whole. Beneficiaries comprise [ active members, ] pensioners, deferred members, and those asserting rights through them, such as dependants.
1.3 The Trustees may, where appropriate, consider the interests of [ insert name of sponsoring employer ] (the ‘Employer’) as sponsor of the Scheme, so long as this does not cut across their fiduciary obligations to beneficiaries. Legal advice should be obtained if it is necessary to determine whether a distinct fiduciary duty is also owed to the Employer.
1.4 The Trustees acknowledge that, at times, their personal interests or other responsibilities may conflict with—or could reasonably be perceived to conflict with—their functions as a Trustee of the Scheme...
Pensions
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