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Pensions Tax Manual

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The lifetime allowance and the lifetime allowance charge: benefit crystallisation events: each of the benefit crystallisation events (BCEs) in detail: BCE 2 entitlement to a scheme pension

Glossary PTM000001
   

 

When does a BCE 2 occur?
The amount crystallising through BCE 2 and relevant valuation factors
Where a chargeable amount arises
A non-standard relevant valuation factor
Definition of ‘P’
Where a scheme pension entitlement is taken before the normal minimum pension age
Where a lifetime annuity is purchased before the normal minimum pension age
Provision of a scheme pension under a money purchase arrangement
Prevention of overlap in a money purchase arrangement
Ill-health scheme pension ceases or reduces (BCE 2 and BCE3)

Sections 165(3)(b) and 216(1)-BCE 2, and 276 Finance Act 2004

Paragraphs 2, 3, 6, 8 and 9 Schedule 32 Finance Act 2004

See PTM088100 for an overview of the benefit crystallisation events (BCEs) and the lifetime allowance.

When does a BCE 2 occur?

BCE 2 occurs when a member becomes entitled to the payment of a scheme pension under a registered pension scheme before the age of 75.

The point at which a member becomes entitled to the payment of a pension is when the right to receive it becomes an actual right as opposed to a prospective right. This issue of entitlement is explained at PTM088200.

This event can occur in a defined benefits or money purchase arrangement, as both types of arrangement may potentially provide a scheme pension.

The scheme pension is tested against the member’s available lifetime allowance regardless of whether it is going to be paid direct from the scheme or whether the future liability to that pension is secured through the involvement of an insurance company.

Deferred annuity contracts

Section 153(8) Finance Act 2004

Where a future entitlement to a scheme pension under a defined benefits arrangement is secured through the purchase of a deferred annuity contract - see PTM062300 then, when benefits are eventually taken from that contract, the scheme pension will still be tested against the member’s available lifetime allowance through BCE 2, as the entitlement to that pension has not altered. BCE 2 is only triggered where the entitlement under that contract actually arises; not when the contract is purchased.

Where a pension commences before normal minimum pension age

Where a scheme pension entitlement arises before normal minimum pension age, and the member does not satisfy the ill-health provision and does not have a protected pension age, a lifetime allowance test will only be triggered under BCE 2 when the member reaches normal minimum pension age.

It is only when the member reaches normal minimum pension age that they are effectively deemed to become entitled to the scheme pension under the lifetime allowance legislation. Earlier payments will represent unauthorised member payments and will be taxed as such. PTM132000 covers this in more detail.

Age 75

The only BCE that can be triggered after an individual’s 75th birthday is through BCE 3 where a scheme pension in payment is increased beyond the permitted margin - see PTM088630.

Scheme pension benefits held in a registered pension scheme in respect of a scheme member that have not been taken by the member’s 75th birthday are valued and tested for lifetime allowance purposes at that point as BCE 5 - see PTM088650.

Because it has already been tested under BCE 5 on the member’s 75th birthday, where entitlement to a scheme pension arises under a defined benefits arrangement after the member has attained the age of 75, that entitlement is not tested through BCE 2 and there is no lifetime allowance test when the pension is taken. A similar position arises where dealing with a money purchase arrangement tested under BCE 5B.

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The amount crystallising through BCE 2 and relevant valuation factors

Where an entitlement to a scheme pension arises under an arrangement in a registered pension scheme, a capital value needs to be attributed to that pension in order to see how much of the individual’s lifetime allowance has been used up at that time.

A relevant valuation factor (RVF)

Section 276 Finance Act 2004

The legislation sets out the method for establishing the capital value of a scheme pension as it comes into payment. It does this by multiplying the annual level of the scheme pension payable at that date by what is called a relevant valuation factor.

The relevant valuation factor prescribed by the legislation is 20.

This factor must be used in all cases, whatever the age or gender of the member at the date of the BCE, unless the scheme administrator has agreed a higher figure with HMRC for scheme-wide use.

Unless a non-standard factor is being used, the crystallised value of the pension is calculated using the following formula

20 x P

P = the amount of pension which will be payable to the member in the first 12 months of payment (or entitlement), assuming that the pension rate at the point of payment continues throughout the period.

The definition of ‘P’ is covered in detail below.

Example

John is entitled to a scheme pension of £10,000 per annum under his defined benefit occupational pension scheme.

Using the conversion factor of 20:1, the crystallised value of that scheme pension for lifetime allowance purposes is £200,000.

Prevention of overlap in a money purchase arrangement

Where, before the member reaches age 75, entitlement to a scheme pension arises wholly or in part from the application of sums and assets taken from their drawdown pension fund or flexi-access drawdown fund under a money purchase arrangement, account is taken of the fact that part of the monies giving rise to the scheme pension entitlement will have already been tested for lifetime allowance purposes through BCE 1 when uncrystallised funds were designated to provide that drawdown pension.

Where the entitlement to the scheme pension arises from the application of a drawdown pension fund or flexi-access drawdown fund after the member has reached age 75, there is no BCE 2 as the only BCE that can occur after the 75th birthday is a BCE 3 - see PTM088630.

PTM062300 explains this and other issues relating to a scheme pension provided from a money purchase arrangement.

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Where a chargeable amount arises

Paragraph 9(2) and (3) Schedule 32 Finance Act 2004

Paragraph 43 Schedule 10 Finance Act 2005

Where a chargeable amount arises, any reduction to the level of scheme pension entitlement made by the scheme administrator to reflect the lifetime allowance charge paid by them is ignored when calculating the amount crystallising through BCE 2 when calculating ‘P’.

However, where either no such reduction is made under the scheme, or the reduction made does not reasonably reflect the tax charge paid by the scheme administrator, based on normal actuarial practice, the tax charge paid by the scheme administrator is called a scheme-funded tax payment and is added to the chargeable amount arising.

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A non-standard relevant valuation factor

Paragraph 11(4)(a) Schedule 32 Finance Act 2004

The standard relevant valuation factor of 20 for valuing scheme pensions coming into payment is based on certain assumptions, one of which is that the pension being provided will not increase annually by more than 5 per cent or the increase in the Retail Prices Index. If scheme rules allow increases of more than this amount, and the standard relevant valuation factor of 20 is used, members are likely to fall within the scope of benefit crystallisation event 3 (BCE 3) in subsequent years of their pension - see PTM088630.

To avoid this, the scheme administrator may approach HMRC and negotiate a relevant valuation factor (RVF) of more than 20 where pensions increase by more than 5 per cent per annum. HMRC cannot agree a RVF that is lower than 20, and nor will it agree a different factor for individual members. Any higher factor agreed must be applied to all BCE 2s occurring on or after the date of the agreement, under any arrangement held by any member under the scheme, in all circumstances.

Unless there are exceptional circumstances, HMRC will only agree to the adoption of a higher RVF if all of the following conditions are satisfied:

  • the scheme has at least 20 members
  • the proposed rate of increase of pensions will apply to all members of the scheme who start to receive a pension on or after the date of the agreement
  • HMRC is satisfied that the proposed non-standard valuation factor accurately reflects the value of pension to be paid, and the proposed rate of increase
  • the proposal is not part of avoidance arrangements to increase the member’s entitlement to a lump sum on which there is no liability to tax.

A higher RVF will mean more crystallises for lifetime allowance purposes under BCE 2 when the entitlement to that scheme pension arises, but may prevent subsequent BCE 3s being triggered, as and when increases are applied to that pension.

Application process

Applications for HMRC agreement to adoption of a RVF factor greater than 20 must be made in writing by the scheme administrator or by an appropriately authorised practitioner to H M Revenue & Customs, Pension Schemes Services (PSS) postal address at PTM011300.

Applications should state:

  • the name of the scheme and its PSTR reference
  • the proposed higher RVF under Section 276 Finance Act 2004
  • the proposed annual rate under Schedule 32 paragraph 11(4)(a) Finance Act 2004
  • the number of members within the scheme, and
  • sufficient detail to enable PSS to establish that all of the above conditions have been met.

PSS may request further information before making a decision. If such information is not supplied within a time specified by PSS when making the request, the application will lapse.

When agreement is reached, PSS will confirm in writing the agreed higher RVF.

The letter will also specify the agreed relevant annual percentage rate of increase in scheme pensions for the purpose of determining whether a BCE 3 is triggered.

The agreed higher RVF and higher rate of increase will apply to all scheme pensions crystallised on or after the date of PSS’s agreement. The agreed higher RVF and higher rate of increases will not apply to scheme pensions or increases in pensions where the individual became entitled to that pension prior to the date of the agreement. Any increase above the normal permitted margin will be a BCE 3.

When PSS cannot agree a proposed higher RVF they will write to the scheme administrator, stating the grounds for refusal. There is no right of appeal against that refusal.

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Definition of ‘P’

‘P’ is defined as the amount of pension which will be payable to the member in the first 12 months of payment (or entitlement) assuming that the pension rate at the point of payment continues throughout the period.

Amount payable in first 12 months

At the point a scheme pension entitlement and BCE 2 arises, it is not necessarily known if the pension in payment will remain the same for the first 12 months. It is therefore assumed for the purposes of BCE 2 that the annual rate of entitlement at the point where BCE 2 occurs, once established, will remain the same for that period whether in retrospect it does or not.

Any actual increase applied to the scheme pension in the first 12 months is tested for lifetime allowance purposes through BCE 3, if it exceeds the permitted margin).

Reduction of entitlement to cover lifetime allowance charge liability

Paragraph 9(2) Schedule 32 Finance Act 2004

Paragraphs 43(2) and (3) Schedule 10 Finance Act 2005

If the member does not have sufficient available lifetime allowance to cover the amount crystallising through BCE 2, the scheme administrator may reduce the member’s pension entitlement in order to pay the lifetime allowance charge due on the chargeable amount arising at that BCE.

This potential reduction is ignored when calculating ‘P’. So ‘P’ is the full entitlement under the scheme before any reduction to reflect the lifetime allowance charge due.

Commutation to provide a lump sum

Where a registered pension scheme only provides the member with a pension commencement lump sum if they give up a proportion of their scheme pension in return, i.e. by commutation, then ‘P’ is the level of pension payable after any lump sum commutation. So the relevant valuation factor would be applied to the pension after commutation in order to obtain the amount crystallising.

The payment of the pension commencement lump sum is a separate BCE (BCE 6), and the cash value of that lump sum is therefore valued separately for lifetime allowance purposes.

Abatement under a public service pension scheme

Paragraph 9(1A) Schedule 32 Finance Act 2004

Paragraph 8(2) Schedule 10 Finance Act 2005

Where a scheme pension entitlement arises under a public service pension scheme, and the starting rate of that pension is reduced through abatement - see PTM062300, this initial abatement is ignored when calculating ‘P’.

For example, if the member becomes entitled to a scheme pension at the rate of £10,000 per annum under a public service pension scheme, but only receives £5,000 per annum to start with due to their continued employment with that public service, then ‘P’ will still be £10,000. The abatement of £5,000 per annum is ignored.

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Where a scheme pension entitlement is taken before the normal minimum pension age

Where a scheme pension entitlement arises before normal minimum pension age, and the member does not satisfy the ‘ill-health condition’ and does not have a protected pension age, a lifetime allowance test will only be triggered under BCE 2 when the member reaches normal minimum pension age.

This includes where the liability for that scheme pension was previously secured through the purchase of an annuity contract with an insurance company.

It is only when the member reaches normal minimum pension age that they are effectively deemed to become entitled to the scheme pension under the lifetime allowance legislation. The pension payments made before the member reaches normal minimum pension age are unauthorised member payments and will be taxed as such. -see PTM131000.

At this point the capital value of the pension in payment at that time is tested against the member’s available lifetime allowance. The amount crystallising is calculated by multiplying the pension payable to the member for the first 12 months following the date on which the normal minimum pension age was reached by the relevant valuation factor that applies, usually 20.

PTM088000 explains why an unauthorised member payment is not tested for lifetime allowance purposes.

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Where a lifetime annuity is purchased before the normal minimum pension age

Where entitlement to lifetime annuity payments arises before the normal minimum pension age and the member does not satisfy the ill-health condition and does not qualify for a protected pension age, a lifetime allowance test is only triggered when the member reaches normal minimum pension age.

It is only when the member reaches normal minimum pension age that they are effectively deemed to become entitled to the lifetime annuity under the lifetime allowance legislation. Earlier lifetime annuity payments represent unauthorised member payments and will be taxed as such.

Where this happens the amount crystallising at that point is not valued through BCE 4. The legislation provides for that annuity benefit to be valued through BCE 2 rather than BCE 4. It therefore treats the lifetime annuity as if it were a scheme pension.

This is done because at that point the capital value of that benefit cannot be precisely identified, as an annuity in payment is being valued not the purchase of such an annuity. So there is no current purchase price.

The amount crystallised is calculated by multiplying the pension that will be payable to the member under the contract for the first 12 months following the date on which normal minimum pension age is reached by the relevant valuation factor of 20.

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Provision of a scheme pension under a money purchase arrangement

Section 165(1), pension rules 4 and 6, Finance Act 2004

Unless a money purchase scheme offers its members the option of taking a scheme pension, such schemes will always value any arising entitlement to a pension benefit through BCE 1 (provision of a drawdown pension) or BCE 4 (purchase of a lifetime annuity contract).

Where a money purchase scheme does offer the scheme pension option, there will be a clear choice for the member (as required by pension rules 4 and 6 - see PTM062300); either to accept the scheme pension quote, or to use the funds held in the particular arrangement(s) to:

  • purchase a lifetime annuity contract through the open market option, or
  • where permitted by the scheme, provide a drawdown pension.

If the member accepts the scheme pension offer, they lose the right to the funds held in the arrangement, and in return are given a certain scheme pension entitlement under the scheme (or with an insurance company through a contract).

The resulting scheme pension benefit will be valued for lifetime allowance purposes through BCE 2, using the RVF x P formula. This applies equally where the liability for that scheme pension is secured through an annuity type contract with an insurance company.

PTM062330 explains the differences between the provision of a scheme pension and the purchase of a lifetime annuity in a money purchase arrangement.

Example of where a scheme pension is provided under a  money purchase arrangement

In May 2006 Brian chooses to draw benefits under his money purchase arrangement. He has £100,000 in the arrangement at that time. The scheme gives Brian the option of taking a scheme pension. When the scheme makes the scheme pension offer they tell Brian his other options. Brian can choose to

  • take the scheme pension offered of £8,000 per annum indexed each year by RPI in return for the funds in the arrangement, or
  • use those funds to purchase a lifetime annuity from an insurance company of his choice on the open market.

Brian sees an independent financial advisor and considers what types of annuity are available in the market, and the sort of rates he can obtain, given his circumstances and the funds available. The best lifetime annuity quote Brian can obtain is a level annuity of around £8,000 per annum. Brian is interested in purchasing an investment linked annuity (linked to the Stock Market). This is an annuity where the income goes up and down depending on the performance of the FTSE 100 share index. Brian can have a pension starting at around £8,000 per annum with such an annuity, but future levels may vary (depending on the movement in the FTSE 100 index).

If Brian chooses the scheme pension he becomes entitled to a pension of £8,000 per annum, increasing by RPI each year, and loses the right to the £100,000 funds held in the arrangement. The liability here is then with the scheme.

The scheme may, or may not, choose to secure their liability for the pension by purchasing an annuity contract with an insurance company. If they do, the contract will only provide the same income as the scheme pension (£8,000 per annum, increasing by RPI). Brian will not be involved in choosing which insurance company the contract is purchased from.

The amount of Brian’s lifetime allowance used up will be calculated by reference to the level of scheme pension payable, not the level of funds given up to secure the entitlement (so it falls within benefit crystallisation event (BCE) 2). The crystallised value of that pension is £160,000 (20 x £8,000) not £100,000. This applies whether or not the scheme liability is secured with an insurance company.

If Brian declines the scheme pension offer and goes down the lifetime annuity route he must tell the scheme administrator what he wants to do, the type of contract he wants and which insurance company he wants them to purchase the annuity with. The scheme administrator then buys that contract from the relevant insurance company.

If he chooses the index-linked lifetime annuity discussed above, his income will start at £8,000 per annum. But the income in subsequent years will vary depending on the performance of the underlying funds. The amount of Brian’s lifetime allowance used up will be calculated by reference to the purchase price of the annuity (as there is no scheme pension entitlement). So it will fall within BCE 4, with the crystallised value being £100,000.

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Prevention of overlap in a money purchase arrangement

Provision of a scheme pension following payment of drawdown pension

The legislation provides rules to ensure that funds held in a registered pension scheme are not tested more than once for lifetime allowance purposes.

A money purchase scheme may give their members the option of taking a scheme pension following a period of drawdown pension, drawn direct from the scheme. A member designates funds to provide a drawdown pension, with the value of the designated sums or assets being tested for lifetime allowance purposes through BCE 1. Then at a later date funds from that drawdown pension fund or flexi-access drawdown fund are applied to provide a scheme pension, either directly from the scheme or through the involvement of an insurance company.

The provision of a scheme pension before the member reaches age 75 still triggers a lifetime allowance test through BCE 2. However, the legislation provides that the amount crystallising through BCE 2 is reduced by so much of the amount that crystallised at the earlier BCE 1 as relates to the drawdown funds being applied to provide the scheme pension. If the amount crystallising through BCE 2 is reduced to nil or a negative amount, then no amount has been crystallised and no lifetime allowance has been used up by the scheme pension entitlement arising on BCE 2. A negative result does not mean that the member’s available lifetime allowance is increased. See the example below.

Where the scheme pension is provided after the member has reached age 75 there is no BCE 2 as the only BCE that can occur after age 75 is a BCE 3 - see PTM088630.

Where only part of the drawdown pension fund or flexi-access drawdown fund is used to provide a scheme pension, or there have been multiple designations

If only part of the drawdown pension fund or flexi-access drawdown fund was used to provide a scheme pension then the above process would work on a pro-rata basis. See example 2 below.

If the drawdown pension fund or flexi-access drawdown fund the scheme pension is funded from has been generated from multiple designations the position is still the same. You would carry out the apportionment by reference to all the previous amounts that crystallised through BCE 1 related to that fund.

Example 1

In the 2011-12 tax year Tony uses all the uncrystallised funds from his money purchase arrangement to provide him with pension commencement lump sum and a drawdown pension. The scheme rules allow Tony to opt for a scheme pension at a later date. Tony is paid a lump sum of £187,500 and is left with a drawdown pension fund of £562,500.

A lifetime allowance test takes place (both BCE 1 and BCE 6 have occurred). The scheme administrator calculates that Tony has used up 50 per cent of the standard lifetime allowance. £187,500 has crystallised through BCE 6 and £562,500 has crystallised through BCE 1.

In the 2015-16 tax year Tony decides to take up the scheme pension option. Tony has taken no drawdown pension so far, and so, because of investment growth, his drawdown pension fund now stands at £650,000. The scheme pension the scheme will provide Tony with in exchange for this fund is £35,000 per annum.

The switch to scheme pension triggers a lifetime allowance test through BCE 2. The amount crystallised is calculated by reference to the scheme pension provided. But credit is given for the amount that crystallised when the funds concerned were originally designated to provide Tony with a drawdown pension. No credit is given for the previous lump sum payment as this was valued and tested for lifetime allowance purposes separately to the designation to provide drawdown pension.

So the amount crystallised is:

20 x P minus the amount crystallised previously through BCE 1

20 x £35,000 = £700,000

£700,000 - £562,500 = £137,500

In 2015-16 the standard lifetime allowance is £1.25 million. The scheme administrator therefore calculates that Tony has used up another 11 per cent of the standard lifetime allowance.

Example 2

Taking the example above, but the scheme rules give Tony the option of splitting his benefit provision and only surrendering part of his drawdown pension fund for a scheme pension.

Tony uses half his drawdown pension fund to secure a scheme pension, giving up £325,000 of his unsecured pension fund for a scheme pension of £17,500 per annum.

The amount that crystallises through BCE 2 is:

20 x P minus a proportion of the amount crystallised previously through BCE 1

20 x £17,500 = £350,000

As half the drawdown pension fund is being used the scheme administrator would discount the £350,000 by half the amount that crystallised when funds were originally designated to provide drawdown pension. Half of £562,500 is £281,250.

So the amount that crystallised is

£350,000 - £281,250 = £68,750

This represents 5 per cent of the standard lifetime allowance in 2015-16.

Where a scheme pension is provided from a drawdown pension fund in existence on 6 April 2006

Article 29 The Taxation of Pension Schemes (Transitional Provisions) Order 2006 - SI 2006/572

Any pension being paid to a member aged under 75 on 5 April 2006:

  • as income withdrawal from a personal pension scheme
  • direct from the funds of a small self-administered scheme (SSAS) in accordance with paragraphs 20.39 to 20.42 of the IR12(2001) Practice Notes on the Approval of Occupational Pension Schemes and the scheme rules did not require an annuity to be purchased for the individual
  • direct from the funds of a SSAS approved under s 590 ICTA 1988 where the scheme rules did not require an annuity to be purchased for the individual, or
  • as income drawdown to a member aged under 75 from any retirement benefits scheme (including a SSAS) within the requirements laid out in Appendix XII of the IR12(2001) Practice Notes on the Approval of Occupational Pension Schemes.

from a money purchase arrangement in a scheme that becomes a registered pension scheme on 6 April 2006 would have become an unsecured pension from 6 April 2006 onwards, then a drawdown pension from 6 April 2011. The sums and assets used for these pension funds are held in a separate ‘ring-fenced’ arrangement to which no further contributions may be made.

Where a scheme pension is later provided from such an arrangement there will be no BCE in respect of so much of the scheme pension that represents the conversion of the drawdown pension to scheme pension. For example scheme pension worth £1 million is provided. Of this, £750,000 of the fund for the scheme pension is derived from an arrangement from the application of funds used to provide income withdrawal from a personal pension before 6 April 2006. So only £250,000 of the scheme pension provision, which has come from uncrystallised rights, is a BCE.

See PTM088300 for more details about pre commencement pensions.

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Ill-health scheme pension ceases or reduces (BCE 2 and BCE3)

Paragraph 2(4)(a) Schedule 28 and paragraphs 3, 4 and 7 to 13 Schedule 32 Finance Act 2004

A scheme pension paid before the normal minimum pension age on grounds of ill-health is tested for lifetime allowance purposes through BCE 2 at the point entitlement arises (using the 20 x P calculation). At a later date payment of that scheme pension may be stopped by the scheme because the member’s health recovers.

When the scheme re-commences paying that scheme pension to the member concerned, for example, because normal minimum pension age has been reached, the re-commenced pension is viewed as still representing payment of the original scheme pension. It is not tested again for lifetime allowance purposes through a further BCE 2. Where such a pension re-commences, any increase in that pension level since the point it was stopped and any later increase in that scheme pension may create a BCE 3.  For the avoidance of doubt, there will be no entitlement to a further pension commencement lump sum when the pension re-commences.

If the member returns to work and becomes entitled to a further pension benefit in respect of their subsequent service, that entitlement may be treated as a new entitlement in its own right under the scheme. The arising pension entitlement would then be tested for lifetime allowance purposes through BCE 2. It might generate an entitlement to a further pension commencement lump sum, tested through BCE 6.

The principles described above will apply also where a scheme pension paid on grounds of ill-health is later paid at a reduced rate rather than stopped completely - see PTM062100.

Example of an ill health scheme pension ceasing

Mark receives his scheme pension of £20,000 per annum early at age 48 due to ill health. The crystallised value of this pension for BCE 2 purposes is £400,000 (20 X P). This pension is increased each year by RPI, so there is no BCE 3.

2 years later, Mark recovers from his illness and returns to work. His scheme pension is suspended (at which point it is £22,000 per annum). Mark works for another 10 years and retires at age 60.

Mark’s original scheme pension re-commences at the rate of £30,000 pa. No further pension commencement lump sum may be paid at that point in relation to the re-commenced pension.

By increasing the £20,000 starting entitlement over the preceding 12 years by both 5 per cent per annum (compound) and the change in RPI, and taking the higher figure, the scheme administrator calculates that if Mark’s scheme pension had continued unabated to that point the permitted margin (see PTM088630) to which his pension would have been allowed to be increased to is £39,508 per annum.

Nothing therefore crystallises at that point through BCE 3 in relation to that pension, as the re-commencing rate of £30,000 per annum is well within the permitted margin.

In addition to the re-commenced pension, Mark becomes entitled to a second scheme pension of £10,000 pa in relation to his ten years’ service after returning to work. This new pension entitlement is a BCE 2 and must be tested against the lifetime allowance. It may also generate an entitlement to a pension commencement lump sum.

The scheme pays Mark a pension commencement lump sum of £30,000 in addition to the £10,000 per annum second scheme pension (with no commutation of pension required).

£200,000 crystallises for lifetime allowance purposes in relation to the new scheme pension entitlement through BCE 2 (20 x £10,000) and £30,000 crystallises in relation to the pension commencement lump sum paid through BCE 6.