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HMRC internal manual

Business Income Manual

Specific deductions: pension schemes: meaning of employer

S279 Finance Act 2004

The special rules governing deductions at BIM46005 apply to any contribution paid by an employer under a registered pension scheme in respect of any individual entitled to receive benefits from that scheme. This includes contributions by an employer to registered personal pension schemes providing benefits for employees. It also includes contributions made by an employer in its capacity as a ’sponsoring employer’ of a multi-employer scheme.

References in this guidance to an ‘employer’ should be read as including a former employer.

Multi-employer schemes

In the context of multi-employer schemes, ‘employer’ also includes any ‘sponsoring’ employer of that scheme.

A sponsoring employer is one of the employers in respect of any or all of whose employees the registered pension scheme has or is capable of having effect so as to provide benefits. Group pension schemes may have most or all group members as participating sponsoring employers (BIM46020).

It should be borne in mind that for a contribution made in respect of another group member’s pension liability to be deductible it must be wholly and exclusively for the purpose of the trade of the sponsoring employer making the contribution. See BIM46030.