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Key definition
Asset definition

What does Asset mean? In legal practice, an asset is any thing of economic value that a person or entity owns or controls and can realise, transfer, secure or enforce. The term is descriptive and used across contexts (company law, trusts, matrimonial finance, probate, enforcement and insolvency), with specific legislation or rules defining it for particular purposes (for example, insolvency, taxation and financial services). Assets include land and buildings, cash and bank balances, securities (shares, bonds and other fixed‑income instruments), receivables, contractual rights (choses in action), intellectual property, goodwill and, increasingly, cryptoassets. Assets may comprise legal or equitable interests and can be tangible or...

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Asset-backed contributions to defined benefit schemes: UK tax treatment under FA 2004 sections 196B–196L, structured finance rules, accounting, qualifying/non-qualifying status, ongoing payments, claw back and restructuring

Practice notes
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Financing defined benefit pension schemes, together with the instability and exposure inherent in such schemes, has posed a persistent challenge for numerous employers over a prolonged period.

asset-backed contribution (ABC) structures offer an option to cut pension scheme shortfalls, serving as a substitute for cash under a conventional contributions schedule framework.

That said, ABCs are inherently intricate, and tax remains a critical factor—both to secure the intended fiscal treatment and to lessen the possibility of any adverse tax effects emerging in implementation phases overall.

This Practice Note sets out a concise outline of ABCs and then examines the principal tax issues relevant to an ABC framework, including restructuring and unwinding, principally governed by sections 196–196L of the Finance Act 2004 (FA 2004), as applicable herein.

For added detail on the nature of ABCs, their role in addressing pension scheme deficits, and the core points to weigh when establishing such an arrangement, refer to Practice Note: asset-backed contributions for pension schemes...

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Ian Cochrane
Ian Cochrane

Ian has been at the forefront of the development of Asset Backed Contribution arrangements for over 15 years. He combines his accounting and tax knowledge with extensive pensions and commercial experience to design and implement bespoke funding solutions for clients....

Web page updated on 21/05/2026

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