Guidance

Pension schemes newsletter 112 – July 2019

Published 31 July 2019

1. Relief at source

a. Annual return of information for 2018 to 2019

The deadline for submitting your annual return of information and APSS590 declaration for 2018 to 2019 to HMRC has passed. However we know there are still returns outstanding from scheme administrators who’ve submitted interim repayment claims for 2019 to 2020. We want to remind you that if a 2018 to 2019 annual return of information was due for your scheme and this is still outstanding, any subsequent interim repayments will be withheld until we receive both the outstanding return and APSS590 declaration.

If you submit your annual return of information but your return fails processing, we’ll still deem this to be outstanding and will stop any subsequent interim repayments pending successful re-submission of your return. If your submission fails for a third time we’ll stop all future interim repayments to your scheme until a further re-submission of your return is received and is deemed successful.

You must submit your annual return of information and an APSS590 declaration. As the declaration forms part of your return, if we receive a return and no declaration we will also deem your return to be outstanding.

You can only submit your 2018 to 2019 annual return of information through the Secure Data Exchange Service.

You must send your APSS590 declaration by email to reliefatsource.administration@hmrc.gov.uk and put ‘APSS590 – Annual return of information declaration’ in the subject line of your email. You can also send this by post to the address on the form.

b. Reporting excess relief

Since we published guidance on the changes introduced by The Registered Pension Schemes (Relief at Source)(Amendment) Regulations 2018 we’ve been asked more questions about how you should report any excess relief you’ve claimed to HMRC. We know that some schemes have continued to report excess relief claimed through their next interim claim, whether or not an annual claim for the year has been submitted.

We know it takes time to change your systems, so you can continue to do this during the current tax year and for the 2020 to 2021 tax year.

As we explained in Pension Schemes Newsletter 110, the transitional arrangements for the information that you must tell us about excess relief that you’ve claimed, ended on 5 July 2019. For your interim claim for 6 July to 5 August 2019 onwards, you must now tell us the information as set out in the regulations but to help you with this we’ve published a spreadsheet that you can use. We’ve added guidance onto the spreadsheet so that when you click on the column headings you’ll see more information to help you provide the right information.

We’ll publish further updates and guidance in future newsletters to clarify the requirements for reporting excess relief claimed, so that you can consider any changes you need to make to your systems for 2021 to 2022 onwards.

2. Pension flexibility statistics

The quarterly release of official statistics on flexible payments from pensions for the period 1 April 2019 to 30 June 2019 has now been published.

HMRC can now give more information on the number of tax repayment claim forms processed for pension flexibility payments.

From 1 April 2019 to 30 June 2019 we processed:

Form number	Number of forms
P55	11,974
P53Z	3,503
P50Z	1,761

Total value repaid: £46,793,765.

Figures for the period 1 July 2019 to 30 September 2019 will be published in October 2019.

3. Annual allowance

a. Pension savings statements for tax year 2018 to 2019

This is to remind scheme administrators that by 6 October 2019 you must issue annual allowance pension savings statements for tax year 2018 to 2019 to your scheme members who made pension savings of more than the annual allowance to your pension scheme.

You can find more information about this requirement in the Pensions Tax Manual at PTM167100.

An annual allowance charge will be due where a member exceeds the annual allowance (and/or money purchase annual allowance) across all pension schemes and does not have sufficient unused annual allowance to carry forward from previous tax years.

b. Declaring the annual allowance charge on the Self Assessment tax return

Please remind those of your members who have exceeded the annual allowance for 2018 to 2019 and do not have sufficient unused annual allowance to carry forward to cover the excess, that it’s really important they declare this on their Self Assessment tax return. They must declare the total amount that they’ve exceeded their annual allowance by for 2018 to 2019 irrespective of who’s paying it.

Members must complete box 10 on page Ai4 of the supplementary SA101 Self Assessment additional information with the total amount that that they’ve exceeded their annual allowance (and this includes members who’ve exceeded their money purchase annual allowance).

If your pension scheme is paying some or all of their annual allowance charge, your member should:

• enter the amount you, as scheme administrator, are paying on their behalf at box 11 on page Ai4 of the SA101 - if they do not do this we’ll ask your member to pay that amount
• put the pension scheme tax reference number in box 12 on page Ai4 of the SA101

The deadline for your members to submit their Self Assessment return for 2018 to 2019 (and supplementary pages) is 31 January 2020.

Your members can find more information about the different types of annual allowance and carrying forward unused annual allowance in tax on your private pension contributions.

Your members can use our Pensions Annual Allowance Calculator to check whether they need to declare and pay an annual allowance tax charge, even if they have not received a pension savings statement.

And there’s full guidance on how to fill in the SA101 in HS345 Pension savings - tax charges (2019).

c. Annual allowance calculator

As we explained in Pension Schemes Newsletter 108 we added the 2019 to 2020 tax year to the Pension Annual Allowance Calculator so that any members of defined contribution schemes who make their total contributions early in the tax year can work out the chargeable amount they should enter in their Self Assessment tax return.

Members should note that if they use the calculator during the tax year and their circumstances change before the end of the tax year, their chargeable amount may be different so they may prefer to use the annual allowance calculator after the end of the tax year when they know what their total pension savings will be.

The calculator automatically produces a result for 2019 to 2020, whether or not pension savings figures have been entered for this year. If a scheme member uses the calculator to check their annual allowance position for an earlier tax year(s), they can disregard the result produced for 2019 to 2010 as this is a default position. Instead, the member should take the results for 2018 to 2019 and earlier years from the table in the calculator.

d. GOV.UK guidance

We’ve updated the following GOV.UK guides on annual allowance:

• tax on your private pension contributions: annual allowance

• check if you have unused annual allowances on your pension savings – this provides guidance on carrying forward unused annual allowances from previous years if a member’s pension savings are more than their annual allowance

• check if you’ve gone above the money purchase annual allowance - this provides guidance to help members work out what their allowances are and if they need to pay tax on their pension savings if they’ve flexibly accessed their pension

• work out your reduced (tapered) annual allowance – this will help members work out how much annual allowance they get for their pension savings for 2016 to 2017 and each later tax year

We’re continuing to work on updating our annual allowance guidance and we’ll provide more detail on this in future newsletters.

4. The Pensions Regulator’s consultation on the future of pension trusteeship and governance

The Pensions Regulator (TPR) has opened a consultation on the future of pension trusteeship, with proposals for how the trustee model can be made more effective.

This consultation is open for 12 weeks, closing on 24 September 2019. You can submit your responses to this consultation through TPR’s website.

5. Qualifying Recognised Overseas Pension Schemes (QROPS) transfer statistics

The annual release of official statistics on transfers to QROPS for the tax year 2018 to 2019 has now been published.

You can find more details at updates for HMRC statistics and statistics at HMRC.