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Masters v HMRC [2025] UKFTT 967 (TC) Employed in the UK by Tesco, Mr Masters had joined Tesco PLC’s defined benefit Pension Scheme back in 1983. In April 2016, he arranged for the cash equivalent value of his defined benefit rights—just shy of £6m—to be transferred into a UK SIPP vehicle. He relocated to Portugal in March 2019 and, from the 2019–20 tax year onwards, was treated as non‑UK tax resident. While living in Portugal he was taxed under the Non‑Habitual Resident regime, benefitting from exemptions on foreign‑source income, which encompassed withdrawals of £3.5m from his SIPP. Nevertheless, those withdrawals were taxed at source in the UK, resulting in £1.5m of tax being paid. HMRC then operated a PAYE tax code on the SIPP pension; Mr Masters sought instead the issue of an NT (no tax) code. In July 2020, he filed his UK self‑assessment income tax return for 2019–20, claiming a repayment of the tax deducted from the SIPP withdrawals, on the footing that the income was not...
Original news Mr S (CAS-30342–Z1B0) – 2 July 2024 Summary The PO has dismissed a complaint concerning a PSO. The PSO was correctly determined at the valuation date as a fixed percentage of the complainant’s cash equivalent transfer value. As the scheme’s unit prices fell after the valuation date, the administrators were right to cash in additional units to ensure the same monetary amount, as calculated at that date, was transferred to the ex-spouse’s pension arrangement. The PO’s decision highlights the challenges that can arise even when there is only a short delay in implementing a pension sharing order. What were the facts? Mr S was a member of the Fidelity Master Trust–Sytner Group Retirement Plan Section (the Scheme). A Pension Sharing Order (PSO) was issued against Mr S’s Scheme benefits. Section 29(2) Welfare Reform and Pensions Act 1999 (WRPA 1999) provided that: “Where the relevant order specifies a percentage value to be transferred, the appropriate amount …. is the specified percentage of the cash equivalent...
THIS PRACTICE NOTE APPLIES IN RELATION TO DEFINED BENEFIT LIABILITIES How defined benefit (DB) liabilities ought to be assessed depends on a number of factors, in particular: the valuation approach to be adopted. Common exercises undertaken comprise the following: scheme-specific funding valuations as required under Part 3 of the Pensions Act 2004 (PeA 2004) solvency (or buy-out) valuations as required by the Occupational Pension Scheme (Scheme Funding) Regulations 2005, SI 2005/337, reg 7 valuations required by the PeA 2004, ss 143 and 179 (often described respectively as s 143 valuations and s 179 valuations) neutral estimates to meet the requirements of Technical Actuarial Standard 300 (Pensions) cash equivalent transfer values (CETV) as specified under the Occupational Pension Schemes (Transfer Values) Regulations 1996, SI 1996/1847 IAS19 and UK GAAP valuations whether the liabilities under review concern past service or future service, as distinct categories This Practice Note sets...
In this Practice Note, the expressions ‘defined benefit’ or ‘DB benefits’ denote safeguarded benefits for the purposes of section 48 of the Pension Schemes Act 2015 (PSA 2015). Likewise, ‘defined contribution benefit’ or ‘DC benefit’ is used for flexible benefits under PSA 2015, s 74. For further detail on safeguarded and flexible benefits, see Practice Note: Flexible benefits vs safeguarded benefits. Relevant trustee considerations When handling DB to DC transfer requests (or DB to DC conversion requests), trustees of DB occupational pension schemes should take account of the following: Compliance with the cash equivalent transfer value regime Trustees must adhere to the statutory rules of the cash equivalent transfer value (CETV) regime. Those requirements are found in: sections 93–101 of the Pension Schemes Act 1993 (PSA 1993), which set out the eligibility conditions and the steps to follow the Occupational Pension Schemes (Transfer Values) Regulations 1996, SI 1996/1847 (the Transfer Regulations), which prescribe how a member’s cash equivalent is to be calculated...
STOP PRESS: On 17 June 2025, the European Commission adopted a package of measures proposing amendments to the EU securitisation regime. Headline elements comprise a lighter due diligence and risk analysis duty for institutional investors in EU securitisations, a shift towards a principles-based approach for securitisations overall, and a lower risk retention requirement for sell-side entities in certain securitisation types. The Commission’s proposals are presently being reviewed by the European Parliament and the Council. There is no fixed timetable for this process, though it is expected to take at least 18–24 months. EU Securitisation Regulation and related legislation—background and purpose In September 2015, the Commission issued the Action Plan on Building a Capital Markets Union. The plan set out a broad suite of measures designed to create integrated capital markets across the EU’s Member States—a Capital Markets Union or CMU—to encourage investment and drive growth. The CMU Action Plan stated that, following the crisis, EU securitisation markets remained significantly impaired, harmed by concerns about the securitisation process and...
Name: ________________________________ Date of Birth: ________________________________ Membership Number: __________________ National Insurance Number: ____________________ Company Name: ________________________ Address: ____________________________________ Date Joined Scheme: ___________________ Date of Leaving: ____________________________ To the Trustees of the [ insert name of scheme ] Pension Scheme (the ‘Scheme’). I have benefits within the Scheme and apply to move the value of those benefits from the Scheme as outlined below. This also covers any amounts that would be paid from the Scheme to my dependants or beneficiaries if I were to die. I confirm I have received a statement of entitlement for my Scheme benefits showing the cash equivalent transfer value (CETV) as at my guarantee date. I wish to transfer my benefits to the Receiving Arrangement(s) listed here: Name of Receiving Arrangement: ________________________________ Address of Receiving Arrangement: ________________________________ HMRC Registration Number: ________________________________ DECLARATIONS Decision to transfer out • The choice to transfer my benefits to the Receiving Arrangement is mine alone,...