Record keeping for pension trustees

As the trustee of a registered pension scheme you are responsible for accurate record keeping to support your tax returns.

Records you must keep

The records you need to keep depend on the particular circumstances of your scheme. Examples of the information and documentation you need to hold on to include (but aren’t limited to):

  • the pension scheme trust deed and rules
  • personal details for each member
  • application forms to join your scheme
  • transfer requests
  • bank statements
  • valuation reports
  • contracts to purchase or dispose of an investment
  • tax vouchers
  • PAYE records and forms
  • schedules of contributions

You must also keep records relating to scheme income and expenditure such as:

  • interest on loans and deposits
  • bank and building society interest
  • interest on UK government securities
  • interest from authorised unit trusts
  • overseas investments
  • trading activities
  • deeds of covenant
  • any monies received by or owing to your scheme
  • any payments made by your scheme

For the tax return you don’t need records that relate to UK dividends.

If your pension scheme has foreign income you need to keep a note of the exchange rate at the time your pension scheme became entitled to the income. You use that rate when you complete your return.

The more detailed records you keep the easier it will be to answer any questions that HM Revenue and Customs (HMRC) has about your tax return. For example you may need to keep:

  • bank and building society statements, pass books, cheque stubs and paying-in slips
  • records of purchases and expenses if there’s any trading activity

How long you have to keep your records

You must keep your records for a minimum period in case HMRC decides to make a check into your return. The dates depend on the circumstances of the pension scheme.

If the pension scheme has business income

You must keep the business records for 5 more years after the normal filing deadline of 31 January. A common example of a pension with business income is a scheme with property to let.

For example, for a 2013 to 2014 tax return filed on or before 31 January 2015 you must keep the records until 31 January 2020.

If the pension scheme doesn’t have business income

You must keep your records for one more year from the normal filing deadline of 31 January.

For example, for a 2013 to 2014 tax return filed on or before 31 January 2015 you must keep your records until 31 January 2016.

If you send the return back after the deadline of 31 January

If you send the return back after 31 January, either because it was issued late or because you sent it back late, you should keep your records until the latest of the following dates:

  • 15 months after the date you sent the return in
  • 5 years after the normal 31 January filing deadline if they are business records

If HMRC starts a check

If HMRC starts a check then you need to keep your records beyond the usual minimum period. You must retain your records until HMRC writes and tells you they’ve finished the check.

If your records are lost or destroyed

Sometimes records are lost or destroyed - for example in a fire or flood - and are difficult to replace. If this has happened let HMRC know and do your best to recreate the missing records. Once you’ve managed to get the replacement information together use this to complete the tax return.

You must tell HMRC whether any figures are:

  • estimated - and you want HMRC to accept these as final figures
  • provisional - you are using these until you can confirm the figures (you must tell HMRC when you will be supplying actual figures)

Use the ‘Additional Information’ section of your tax return form to tell HMRC how you’ve arrived at these figures and the reason why you can’t use actual figures. If you make adjustments at a later date and you’ve underpaid tax you may have to pay interest and penalties.

HMRC checks into your tax return

If HMRC decides to start a check on your tax return they will write and tell you:

  • that they are starting a check
  • what they are checking, for example your tax return (or part of it) or a claim you’ve made
  • what information you need to provide
  • when you need to provide it by

HMRC normally has 12 months from the date you sent in your tax return to tell you that they intend to start a check. They may have longer if you’ve changed your tax return, sent it in late or where the information you supplied was deliberately misleading.

Getting help and advice

Administering a pension scheme can be complex. If you’re already a trustee or you’re thinking about becoming one you may want to get advice from a solicitor.

You may also find it helpful to talk to a tax adviser or accountant too. If you have any problems completing your tax return, please contact Pension Schemes Services.

Search for a solicitor on the Law Society website

Find a tax adviser at the Chartered Institute of Taxation website

Find a chartered accountant on The Institute of Chartered Accountants in England & Wales (ICAEW) website

Published 16 September 2014