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THIS PRACTICE NOTE RELATES TO REGISTERED PENSION SCHEMES By means of Schedule 4 to the Finance Act 2016 (FA 2016), the government brought in an allowance protection regime designed to sit alongside the cut in the lifetime allowance from £1.25m to £1m on 6 April 2016. Termed fixed protection 2016 (FP 2016), it mirrors earlier fixed protection regimes respectively launched on 6 April 2012 (fixed protection 2012, or simply ‘fixed protection’) and 6 April 2014 (fixed protection 2014). This Practice Note focuses on FP 2016, which is the subject of this Practice Note. The original purpose of FP 2016 was to give transitional protection to people who, before 6 April 2014, had already accumulated pension savings above £1m, or who expected to do so on the basis that the lifetime allowance would be maintained at no less than £1.25m. Although the lifetime allowance was removed with effect from 6 April 2024, FP 2016 still delivers limited transitional safeguards regarding an individual’s rights to (i) the lump sum allowance, (ii)...
THIS PRACTICE NOTE RELATES TO REGISTERED PENSION SCHEMES Enhanced protection was among the initial two protections available to pension savers on A‑day (6 April 2006), when the registered pension scheme framework and the lifetime allowance concept were first brought in by the Finance Act 2004 (FA 2004). The second protection launched on A‑day was primary protection. In contrast to primary protection, anyone could apply for enhanced protection irrespective of the amount of their pension rights as at 5 April 2006. The purpose behind enhanced protection was to deliver transitional cover for individuals who, before A‑day, had already accrued pension savings that might otherwise have been negatively impacted by the advent of the lifetime allowance (which on A‑day stood at £1.5m). Although the lifetime allowance was removed with effect from 6 April 2024, enhanced protection still affords limited transitional safeguards in relation to an individual’s rights to (i) the lump sum allowance, (ii) the lump sum and death benefit allowance, and (iii) a tax‑free lump sum. For additional detail, see...
Ways of providing death-in-service benefits Employers commonly provide their staff with death-in-service benefits (often referred to as 'life assurance' or 'life cover' benefits). This protection is ordinarily limited to employees (hence the term 'death in service', reflecting the label itself), although in certain situations an employer may decide to extend the benefit beyond retirement. Employers can deliver these benefits in three ways: via a dedicated trust-based arrangement that, while registered as a pension scheme for the purposes of Part 4 of the Finance Act 2004 (FA 2004), provides only death-in-service benefits—such arrangements are frequently known as 'life cover only schemes', 'death-in-service schemes' or 'standalone life assurance schemes', and no other benefits through a registered pension scheme (usually an occupational pension scheme) in which the death-in-service benefits form part of the broader benefit structure of the scheme as a whole. In this type of arrangement or model, a scheme member may receive: both death benefits (including death-in-service benefits) together with...