So what does Mr Clara make of the Stagecoach/Aberdeen deal?

We’re now in the aftermath of the Aberdeen transfer of the Stagecoach pension from Stagecoach PLC’s to its responsibility.

I know people get fed up uncovering these papers so here is what Adam and his mates are saying!

 

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Why do people move or stay put? Hamptons know more than most.

Where I moved from – when I was 18 – Shaftesbury

Upward house price growth in London is no longer the one-way bet it once seemed. Hamptons’ analysis of Land Registry data, which compares the price homeowners paid for their property with the price they sold it for, shows that in 2025, 14.8% of London sellers sold for less than they originally paid, overtaking the North East, which held the top spot in 2024.

In some cases, even owners who bought a decade ago still face getting back less than they paid – something that would have been almost unthinkable in the heady days of 2015. And for many, the sums are tight.

In fact, the North East had dominated the loss-making rankings for nine of the last 10 years. As recently as 2019, 29.9% of North East sellers sold for less than they paid compared with 9.2% in London, reflecting the region’s slow recovery from the 2008 financial crash.

But that picture has shifted dramatically. The share of loss-making sales in the North East has more than halved over the past decade, falling from 29.9% in 2019 to 17.7% in 2024 and just 13.9% in 2025.

In contrast, London’s figure has been rising, underlining the reversal in fortunes between North and South. This trend has been driven largely by flat sellers who, despite accounting for 60% of London sales last year, represented 90.0% of homes sold at a loss, up from 78.4% in 2019.

At local authority level, eight of the 10 local authorities where sellers were most likely to make a loss were in the capital. Last year, 28.2% of sellers in Tower Hamlets sold for less than they paid, the highest figure in both the capital and the country, with flats making up 90%+ of all sales in the area.

The City of London (26.2%), Kensington & Chelsea (22.4%), Westminster (22.1%) and Hammersmith & Fulham (20.8%) complete the top five local authorities where more than a fifth of sellers sold at a loss in 2025. Meanwhile, in Barking & Dagenham – London’s cheapest borough – just 5.3% of sellers sold below purchase price.

While the average London seller in 2025 still achieved a price of £172,510 (44.6%) above what they originally paid, most of this uplift stems from historic house price growth. Although half of London sellers last year had owned their home for more than a decade, in cash terms, these long-term owners accounted for 77% of the total gains.

Over the next few years, more sellers are likely to have missed out on London’s 2012-16 house price boom, having bought instead at what turned out to be the top of the market. That could make trading up increasingly challenging.

House owners in the capital generally recorded higher gains than flat owners – 59.6% over an average of 10.3 years, compared with 35.4% for flats over a similar 10.1 year period. London house sellers were more than six times less likely than flat sellers to make a loss (3.5% vs 22.2%). This widening gap has made it increasingly difficult for flat owners to bridge the step up to a house.

Elsewhere, sellers in the South of England (South East, South West and East of England) were also among the most likely to sell for less than they paid. While sellers in three of the four Southern regions achieved smaller average gains than in 2024, vendors in all three Northern regions saw increases.

Nationally, rising gains in the North have helped offset shrinking returns in the South, leaving the overall picture broadly unchanged from last year. And with much of the recent price growth in the North and Midlands now baked in, it’s possible that seller gains there could outpace those in the South – in both cash and percentage terms – for the foreseeable future.

In 2025, the average seller in the North West achieved a 45.4% increase in the value of their home during their period of ownership; higher than London (44.6%), the South East (38.3%), South West (39.5%) and East of England (39.5%). Outside London, no southern region recorded average gains above 40%.

Nationally, the picture in 2025 was similar to 2024. Last year, the average homeowner in England & Wales sold for £91,260 (or 41%) more than they paid an average of 9.0 years ago. This figure was £570 less than the £91,830 average gain recorded in 2024.

Across England & Wales, 8.7% of sellers in 2025 got back less for their property than they originally paid, down slightly from 8.8% in 2024. However, this figure masks a sizable divide between property types: 19.9% of 2025 flat sellers sold at a loss, compared with just 4.5% of house owners, down from 5.7% in 2024.

The recent slowdown in house price growth nationally is likely to reduce the uplift homeowners achieve when they come to sell in the coming years. But for many, moving remains a discretionary decision, heavily influenced by the value they can achieve.

If the numbers don’t stack up – and sellers risk losing part of their original deposit – many choose to stay put. This means some homeowners, particularly those unable to secure a gain, are likely to remain out of the market.


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David Fell

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The Missing Voices of pensions!

There are two voices among trustees that provide a fascinating contrast. John Hamilton (not a professional but a chair of trustees)  is calling for trustees and employers to pay more attention to the implications of decisions on “end game” while Alison Hatcher (a professional trustee is calling for the voice of the trustees to be heard.

What we are seeing is a change in the weight of voice from trustees since the arrival of the pension schemes bill and I think it is the outcome of a Government (both DWP and Treasury) who are looking for pensions to take a lead.

I have worked with both John Hamilton and Alison Hatcher over the past three years and seen how they have moved from peripheral to central to the conversation. The new Aberdeen Stagecoach scheme and Vidett are now instances of change and touchstones for people’s view of professional pensions. Who would have thought that that would be the case in the early years of this decade let alone what came after the Financial Crisis.

It is this new self confidence in themselves that gives trustees a new voice, a voice that has been missed when the voice of pensions was subdued and given outlet mainly through the Pension Regulator and through actuarial consultancies.

The comments that follow John Hamilton’s post and Alison Hatcher’s article confirm this newfound confidence. Monty Hadadi is another voice of this new generation of spokespeople who have been given the space and voice to speak their mind.

I cannot see the Pension Schemes Bill getting properly enacted without these people at the fore. They are the missing voices of the past twenty years , voices that we went into this century with but which we lost in the misery of the collapse of defined benefit in the private sector and the terror of “de-risking” that throttled innovation and growth.

I see what is going on in the House of the Lords this week, the amendment of the Pension Schemes Bill to make it better, to give DB schemes a chance to run as a key part of this and I would add several members of the upper house who are making progress happen.

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Anthony Manchester; Global Policy as seen by BlackRock’; 10.30 today

Coffee Morning – In conversation with BlackRock’s Antony Manchester 

Attending CPD included

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We did as we were told, not as we chose; VFM for workplace pensions.

I cannot understand who a value for money assessment is for if it is not for the regulator.

Who takes choices on the provider of workplace pensions if no choice needs to be made? The vast majority of choices were taken by accountants who simply point employers towards providers who work with their payroll. This is how NOW became a leading provider (it certainly wasn’t for anything else). The HMRC choice is a GPP called Collegia who have the best part of 5,000 small employers working with them to fund employee’s retirement. Nest has 14bn workers with money.

To suppose the reality of saving is going to be determined by a four-shade rating flies in the face of reality. Workplace pension saving is determined by regulators and providers -by payroll!

What will matter to workplace pension providers is what they are made to do by the Pension Regulator and the FCA (see above). This is not a consumer rating unless it touches ordinary people at the point when they are taking decisions on what to do with money they have built up for retirement.

If I was rating credit or owned the equity of a workplace pension provider, I would be paying attention to the ratings as they could have a serious impact on a firm’s profitability and in extreme solvency. But there is little that will be done for the saver who is on the wrong end of poor investment, incompetent service or undisclosed charges.

Torsten Bell has made it clear that people will be made aware of the performance of their provider and we can be sure that the press will do what they can to make it clear to people whether they have got lucky or not. But that is the end of it. There is nothing in the value for money consultation that makes me feel that I would be rewarded if my provider was marked “red”.

All that we as consumers are getting is a heads up when we pay attention to our pensions , of what has happened. When I started Pension PlayPen in 2013 , it was with the aim of employers having a certificate signed by an actuary saying that they had a decision having conducted due diligence. Only around 17,000 employers got that far and I doubt that many of those certificates (digital or printed) are sitting on a file.

The truth is that the vast majority of decision making was taken with no due diligence on the provider and just with the assurance of regulation. There were a few rogues early on, but not many. Nimble young providers such as Smart took over workplace pension systems that were no good and (as far as we know) there are no scandals in workplaces where money has gone astray.

What we are left with is a retrospective view of what happened to our money which will become available at about the time our pension values are delivered on a pension dashboard.  It will not take a miracle of technology to allow the information from the dashboard to be linked to the VFM dashboard assessment and for savers to see retrospectively what Pension PlayPen wanted to show on a forward basis.

Below is an example of a rating we did in our early days (2013). The harsh reality is that how your workplace pension has grown in the thirteen years since bears no relation to the predictions me and my friends at First Actuarial doing the research made. Our top performer (NOW:pensions) turned out to under-perform though there will be those in new owners who will argue that that could be different on a “forward” basis. The great successes, People’s , Nest and L&G who are all “sized” satisfactorily to keep going , were all quoting then and they have been joined at the top table by Willis Towers Watson’s LifeSight.

But I have to admit defeat. Despite running Pension PlayPen throughout the enrolment period (2013-18), we could never catch the nation’s imagination. We were told that Value for Money would only become important when there was money on the table.

Well now there is. Now most people who are older than 55 (when you can still take your money)  People will be looking at there various pension pots from differing employers and working out which will be good for them, which less so.

Here the VFM ratings will be used. The re-organisation of providers resulting from VFM tables is likely to see further transfers to the workplace pensions that survive and a level of engagement from consumers we have not seen before.

Even so, the vast majority of decisions will be taken by our regulators and by providers , their trustees and their IGCs will have some influence.

Nostalgia

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Why we and the Dutch shouldn’t confuse pensions with pension balances!

Peter Van der Nat

I am trying to get a grip on UK pension reform by looking at what the Dutch are making of their “WTP”.

The Future Pensions Act (DutchWet toekomst pensioenen, abbreviated Wtp) is an amendment to welfare law in the Netherlands.

This law revises the Dutch pension system and amends thirteen laws, including the Pension Act. The law came into effect on 1 July 2023, and pension funds currently have until 2028 to switch to the new system.

I came across this post on pensions and it helps me understand the confusion the Dutch have between pension balances and pensions. It is a problem we have had with CETVs and I would like to get Peter van der Nat’s post on the blog’s board!

This is a problem that the Dutch will have with putting a value on people’s pensions even though they won’t be able to encash the pension. I see no sense in it. We had this fiasco in the UK in the last five years of QT when depressing interest rates (and gilt yields) drove up CETVs (cash equivalent transfer values). The point at which transfer values on DB pensions were at their highest was the point when those pension schemes could least afford to pay such transfers. CDC will not get into that mess so long as they avoid guaranteeing anything.

The Dutch system of pensions allows people to see their pension values going up and down when in the CDC scheme by declaring a theoretical value without giving them access to that money as a cash out. It’s a bit like the value of the house you live in, it may go up or down but to you it’s value is in the comfort and protection it gives you  – and the happiness.

I don’t know Peter van der Nat or how I came into possession of this clip from Linked in. He works for Howden – a very British company which has now reached into 65 countries. We need to take a step back and see if we can find some common ground between the Netherlands and the UK as we move towards CDC and work like Peter’s is part of that process.

I think that the Dutch’s wish to give people the value of their CDC rights by way of “balances” is misguided. It is merely of value to actuaries in pricing pensions purchasable with contributions (and transfer ins). This balance means nothing to the ordinary person just as their CETV meant nothing (unless they chose to take it). Giving people a balance of their rights when they are in their CDC scheme is just a recipe for discontent.

What we are moving to , in the UK , is a valuation of our DC rights in terms of pension rather than pot. It is what we will get as our balance when we look at our pension dashboard and we will only be able to see the balance (as the Dutch call it) by digging into the information presented by the dashboard.

The Dutch are confusing the pension (the amount we get each month to spend) with the balance (the cost of paying that amount until death). It would be a very retrograde move if we were to give prominence to a balance over a pension on our dashboard and certainly on our CDC pension.

As Peter’s snip shows , the value of people’s balances has gone down recently but their pension is exactly as expected. How can this be? Quite simply explained in actuarial terms but hugely confusing for those outside financial circles.

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The American view of Dutch Pensions – tickled!

Today’s financial Goldilocks moment—with strong equity returns and robust fixed income yields—creates favorable conditions for the Netherlands to complete its long-planned switch from traditional private defined benefit plans to ‘collective defined contribution.

‘You can almost call it a tontine,’ a Dutch pension consultant told Retirement Income Journal. (RIJ)


As of January 1, 2026, private defined benefit (DB) pensions in the Netherlands have begun converting to collective defined contribution (CDC) plans, as mandated by the Future of Pensions Act, enacted by the Dutch parliament in mid-2023.

An estimated 9.5 million individual pensioners with savings of €1.8 trillion are on the move. By January 1, 2028, all of the Netherlands’ employers, unions, insurers, and premium pension institutions must comply with the new rules.

CDC is a hybrid of 401(k) and DB. In the Dutch version of CDC, workers and employers make mandatory tax-deferred contributions (27% of pay; 18% from employers and 9% from employees) to collectively-managed funds.

Relative to DB fund managers, CDC managers have more latitude to invest in high-yield alternatives, like private credit. Some observers predict that CDC could deliver a 7% increase in retirement income pay­ments. The manager of the largest pension fund estim­ates the trans­ition could boost invest­ment in private equity and credit invest­ments by about five per­cent­age points—or €90bn—over the next five years.

While participants have “personal accounts,” and accumulations at retirement depend largely on contributions and performance of the collective fund over their lifetimes, the accumulations are not liquid and are paid out only as annuities starting at age 67. A rule that might allow 10% lump-sum distributions at retirement is still in limbo.

“Participants can see their returns and their costs online, but with the collective mandate they don’t control their own pots,”

Annette Mosman, CEO of APG, manager of the civil service pension plan ABP, the largest Dutch pension fund.

“There are 20 life-cycle groups [with age-appropriate asset allocations, target-date funds]. The normal retirement age is 67. When you reach age 55, most schemes will let you see what your benefit will be at 67, based on your current salary and assumed returns of 4% to 5%. Our target replacement rate is 70% of the average salary,”

she said.

“You could almost call it a tontine,”

Jorik van Zanden, a pension consultant at AF Advisors in Rotterdam, told RIJ. No government, corporation or insurer provides guarantees that participants will receive a fixed or rising income for as long as they live. Instead, the fund is managed for long-term sustainability. When participants change jobs, their savings follows them.

Dutch unions, employers and government started talking about DB pension reform some 15 years ago, when low interest rates were crippling plans’ ability to pay inflation-adjusted benefits. Today’s financial Goldilocks moment—with strong equity returns and robust fixed income yields—creates favorable conditions for the change. Workers’ accrued benefits in their old plans are credited to their new plans.

Each industry sector in the Netherlands designs its own pension plan and chooses among more than 100 fund managers. Participants in each plan pool their longevity risk; when participants die before retirement, their notional share of the assets remains in the plans.

Participants also share investment risk. Ten percent of contributions go into a “solidarity reserve.” With market appreciation, the reserve can grow to as much as 30% of the value of the fund. If losses at the fund level threaten to reduce the fund’s ability to meet targeted payout levels (70% of the average wage), the reserve makes up the difference.

“So, if I retire a day before a crash, there’s a possibility that the buffer will dampen the impact,” van Zanden said. It’s called a solidarity reserve, because, by funding a buffer fund, the young to some extent might be paying for the old. In the Netherlands, we prefer certainty to the possibility of higher income.”


“The reserve or buffer will be use when markets work against us, and makes sure that no groups see their benefits shortened,”

Mosman told RIJ. It’s worth noting that Dutch CDC entails a single fund into which money is contributed and invested and from which benefits are paid, rather than having two: a risky accumulation fund and a safe distribution fund.

The single-fund approach makes the “smoothing” mechanism possible, keeps all the money invested for potential “raises” in payout rates, but eliminates any chance of guaranteed lifetime income.

There are more than 100 pension funds in the Netherlands, with some €2 trillion under management. The three largest are ABP (for civil servants), PFZW (for the health and welfare sector), and PMT (for engineers and metal workers). They account for about two-thirds of total private pension savings. Dutch plans invest globally and have no obligation to buy Dutch government bonds or to support any particular Dutch industry sector, Mosman said.

Like many countries, the Netherlands has adopted a “three-legged” retirement security model. There’s a basic “first-pillar” pension (the “AOW”) that accrues at the rate of 2% a year for everyone who lives or works in the Netherlands. It is pegged to half the minimum wage. In 2025, the gross monthly payment was €1,580.92 for a retired single person and €1,081.50 for each member of a retired couple, excluding an 8.00% holiday allowance paid annually in May. For those with excess savings, there’s also a “third-pillar,” which resembles U.S.-style 401(k) plans.

For the Dutch, the British and American practice of swapping out a DB plan with a group annuity issued by an insurance company (via a pension risk transfer, or PRT) wasn’t an option, because retirement plans are designed at the industry-sector level, by management and labor, and not sponsored by single employers.

The American practice of closing a DB plan and offering a simple 401(k) wealth-accumulation plan to new employees wasn’t possible in the Netherlands either, where workers had grown accustomed to pensions.

“Each industry sector had a choice between a ‘flexible’ CDC variant and ‘collective/solidarity’ variant. The flexible variant is more like U.S. defined contribution. Most sectors chose solidarity, which surprised many of us. This variant is a good midway point between DC and DB,”

Mosman told RIJ.

“It allows the social partners in each plan—the unions, employers and the government—to choose the size of their solidarity reserve. Their actuaries have to demonstrate that the size of the buffer works for all of the age-cohorts in the plan. The reserve or buffer will be use when markets work against us, and makes sure that no groups see their benefits shortened.”

It’s hard to imagine American workers giving up the liquidity and self-directed investing aspects of 401(k) plans, and equally hard to imagine U.S. employers accepting mandatory contributions (on top of payroll taxes). Some U.S. 401(k) plan sponsors are embedding optional deferred annuities in their plans.

But most Americans, unaccustomed to thinking about their 401(k)s as retirement income vehicles, have yet to embrace such options. History suggests that it’s easier for workers to convert to a CDC plan if they’re coming from DB plans—where there was no liquidity—than if they’re coming from DC plans—where there was.

“Life-contingent savings and payments only work when they’re compulsory,”

Per Linnemann, a former chief actuary of Denmark, told RIJ.

 “It would not be attractive in the Anglo-Saxon countries and in Denmark, where you have a choice.

“It may be more appealing to combine income-drawdown with longevity-sharing and survivor benefits at a very old age, when they have the biggest impact,”

he said.

“By that time, the bulk of the savings will have been paid out as retirement income. This may mitigate participants’ loss aversion when facing the risk of losing a large proportion of their savings if they pass away early in retirement.”

Linnemann is describing, in effect, a program of systematic withdrawals from investments starting at retirement, coupled with a deferred income annuity starting at age 80 or later. Retiree with adequate savings can create such plans themselves, but they’d pay retail for the annuity.

Companies in the Netherlands that don’t belong to any existing sector can choose the flexible variant of the new system, which is like a 401(k), and doesn’t require mandatory contributions to a CDC pension—if they don’t belong to any sector that has a pension.

Booking.com, for instance, claimed that it was a tech company, not part of the Dutch travel sector.

“The new corporate models don’t want mandatory contributions. But that’s the strength of the system,”

Mosman told RIJ.

Last March, the Dutch Supreme Court rejected Booking’s claim and must participate in the travel sector CDC. The ruling forced the Amsterdam-based company to sign up for the scheme and make back payments dating from 1999, at an estimated cost of more than €400 million.

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My home is no longer my pension – London estate agents tell me!

It is a recurring theme that plays in my head from my days selling pensions to my peers back in the 1980s and 1990s (when it was my job).

“My house is my pension”

Those of us. many of us, who had purchased at up to 100% of the value of the property were sitting on equity that so outweighed the value of our personal pensions to make the comparison useless, we would have enough money from property to sell up or rent out of borrow against our property and what was the need of saving pounds a month into a pension pot?

What we did not expect is what many people have got, a maudlin market and in some cases, such as leaseholds in London, a falling market. The FT report the widespread incidence of people selling their flats at a loss.


Valentina Romei reports for the FT.  A higher proportion of homes in London were sold at a loss than any other region in England and Wales last year, according to a study, in the latest sign of weakness in the capital’s property market.

Hamptons’ analysis of Land Registry data shows that 14.8 per cent of London sellers sold for less in 2025 than they originally paid, above the national average of 8.7 per cent.

It is happening in my block where people at flat-holder meetings say they are not selling because they can’t cover their mortgage or because it leaves so little equity that there is insufficient to make the move to anywhere they like (they live in a lovely place in the City of London).

But one person said to me that she had hoped that she could sell her home to give her cash in retirement to “bump up” here meagre retirement savings and I suspect that more in the room were of the view that the place in the City might be worth some release of equity. The harsh reality of the situation came over us when we found we were all in the same boat.

Of course it is worse for leaseholders, caught in the grasp of freeholders with ground rents and service charges making it feel like renting (even when on 90 year leases).

Aneisha Beveridge, head of research at Hamptons, said:

“In London, upward house price growth is no longer the one-way bet it once seemed.

In some cases, even owners who bought a decade ago still face getting back less than they paid, something that would have been almost unthinkable in the heady days of 2015,”

she added.

This is the picture that Hampton have found from their research.

There are very few “flat for sale” signs up in my part of the City. Many of us are waiting for some news from the Government to get our neck out of the noose that freeholders have it in. But it is more than just the leaseholder problems, the fact is that property in London and the posh areas around it, is no longer a deliverer of pensions through the owning of property.

I’m sorry but that fool you remember coming to your door with a fact-find and an application for a personal pension may have had to be right at some point, It took many years for the euphoria of property ownership to turn to ennui but it has.

My property will not be my pension and never should have been thought of being. Pensions are the sensible way forward, boring as their progression may seem. We in London are just learning how it feels in other parts of the country!

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Why it’s easier for bankers to do private credit – but is it better for the rest of us?

Doubt has been shed on the objectivity of the discussions in the House of Lords. They’ve been carried on by former partners of City Solicitors. 

My correspondents Tim Simpson and Byron McKeeby have been going at each other over selective discussing and selective reporting (in the case of Citywire)

If we are interested in private credit, and I think we ought to be, it’s worth getting to the bottom of what these lawyers said in the House of Lords discussions , complete rather than selective. Here’s Byron in conversation with Tim ..they’ve been arguing over an incomplete account from this Citywire.

As for Citywire’s selective reporting of the report, that’s why I posted a link to the whole report, which if it’s so relevant is either worth reading in its entirety, or not.

I leave interested parties to draw their own conclusions to these particular exchanges in oral evidence to the Committee, which seem the basis for Citywire’s selective reporting:

Here is what he posted

We may agree to disagree whether the Lords, and this particular Committee, is worth retaining, Tim.

See what you think, if this is a compromised committee, then I’m not sure what a good one is.


Lords Committee:

“During the oral evidence session with the Committee, HM Treasury did not reassure us that it has a firm grasp on the emerging issues related to private markets and their potential impact on financial stability. (Paragraph/Question 181)”

Relevant Witnesses were Lucy Rigby KC MP, Economic Secretary to the Treasury and City Minister; Lowri Khan CB CBE, Director of Financial Stability, HM Treasury; and Daniel Rusbridge, Deputy Director for Personal Finances and Funds, HM Treasury.


Lord Grabiner (Lords Committee): I have a couple of points that I would like to ask you about. First of all, arising out of Lord Sharkey’s question, in terms of what I would call plan B, which is in anticipation of another horrible GFC on a worst-case scenario, can we assume that there is a continuing dialogue between the Treasury and the regulators, and that you are not exclusively reliant upon the regulators to blow the whistle or let the red lights flash in the event of an anticipated similar catastrophe?

Lucy Rigby (HMT): As to the first point, you can certainly assume that there is a continuous dialogue, which is, I hope, entirely as you would expect. As the Treasury, we have a role in overseeing things. That is clearly not in the supervisory and granular way that the regulators do, but we would consider ourselves to have an important role in the process, and I say that as to financial stability more broadly.

Lord Grabiner: I hope so.

Lowri Khan: If I can add briefly to that, there are various formal ways in which we have a role, and there are more informal ways in which we have an ongoing dialogue. In particular, the Financial Policy Committee has a Treasury member. They are a non-voting member, but that means that we are present at all the meetings of the Financial Policy Committee and very much in the swim of those deliberations.

We are also present in the global Financial Stability Board as well. We do not just leave it to the Bank and the regulators in those fora. We spend a lot of time on cross-authority dialogue with the Bank, the FCA and the PRA. That is a daily matter. It is not a quarterly meeting for a catch-up. In that engagement, we focus particularly on some of the specific risks as well as on potential policy matters that might be pursued.

Lord Grabiner: That is very good. It is good to know. My other point was touched on by Lord Eatwell, and this will be very close to the Minister’s background as a competition lawyer. We have been told that bank lending through private credit only requires the individual bank to hold 20% of the risk-weighted capital, whereas, if banks lend directly to a company, they have to hold 100% of that capital. I am just an ignorant lawyer, really, but you are a competition lawyer, and you probably know the answer to this question. What is the justification for that discrepancy?

Lucy Rigby: Across the board, there is an acknowledgement that the banking sector as a whole is competitive, which is to the benefit of the wider economy. As to the stipulation that you are pointing to, Lord Grabiner, your suggestion is that it creates an uneven playing field. Is that right?

Lord Grabiner: It encourages banks that want more flexibility on their lending book to lend to the private market. They will be discouraged from lending because they would have to hold so much more capital to justify the loan. What I do not understand is why there is that discrepancy in the first place. There may be some economic explanation, but I am not quite sure what it is. Do you know?

Lucy Rigby: It is right to say that capital requirements right across the board—as you know, there are different requirements that apply to different levels of the stack—are put in place with a view to the size of specific banks and their specific lending activity. You will know that the FPC is reviewing capital requirements, and that review comes on the back of reforms that have been made recently, including to MREL [Minimum Requirement for Own Funds and Eligible Liabilities]. Because of the FPC review and reforms that have been made, there is an impetus for making sure that the banking sector is as competitive as possible, and we recognise that capital requirements are a piece of that.

Lord Grabiner: Finally, if that split of 20% and 100% is accurate, is that a source of concern to the Treasury? Does it give you concern because of the lack of knowledge about what is going on there in terms of potential exposure and potential risk?

Lucy Rigby: Lord Grabiner, I am going to turn to my officials on that. It is not something that has been raised with me in this context.

Lowri Khan: I cannot comment in detail on the specific capital that is held against specific investments.

The Chair: Why can you not comment on it?

Lowri Khan: I am not aware of the specifics. It will be context-specific.

Lord Grabiner: It is a pretty basic point, is it not? You must have thought about this. I hope somebody has thought about it.

Lowri Khan: Yes, indeed. To be clear, the way that risk weightings are applied generally to bank lending is an active area of consideration. There is ongoing work, for example, in the context of the PRA, thinking about how internal models can be made more accessible to smaller banks in particular, so it is definitely an active area.

Byron McKeeby: My question is slightly different. Should we be concerned about the fact that a lot of money is going from banks into what we call private credit? We do not have any visibility of what is going on in that marketplace. At the moment, banks are, presumably, also encouraged to lend more to that marketplace because of the much better risk weighting commitment that the individual bank is confronted with in respect of that lending profile.

Lowri Khan: That is understood. Clearly, we would be concerned if there was anything very distortionary going on.

Lord Grabiner: But you do not know that, or do you?

Lowri Khan: There are several dimensions to this. One is what it means for the safety and soundness of banks. A lot of work is being done in the context of the regular bank stress testing that goes on to ensure that those exposures are being managed.

Lord Grabiner: That goes to the position of the individual bank.

Lowri Khan: Yes, indeed.

Lord Grabiner: The bank is being stress-tested in terms of what its book looks like and, if things go wrong, what is going to happen to the book. What about what is going on outside in terms of the borrowing in that private marketplace?

Lowri Khan: You are right that the stress testing looks at it from the bank’s perspective, but it does consider the bank’s ability to manage its exposures. There has been particular work by the PRA to try to think about how well individual firms are managing their exposures in the round.

Thanks to Byron for alerting us to this dialogue. It suggests to me that private credit may not have quite the credibility we thought of it.

Following on from inquiries from the FT and Reuters , I am going to stay clear of lines of private credit drifting my way on my pensions.

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Occupational Pension Schemes (from an Employer’s perspective).

This article is from Peter Cameron-Brown, a trustee of an active defined benefit pension scheme. It’s audience is primarily experts though it is sufficiently well written to be understood by someone like me. I recommend it to you.

 


Options with an existing Defined Benefit Pension Scheme

I am concerned that Employers with an existing Defined Benefit pension scheme, whether closed or open to accrual, are not being fully advised on the implications of the various alternatives open to them.  I consider that there is too much attention paid to a commercial insurance product “end game” for a DB pension scheme without adequate consideration of the future pension scheme arrangements and hence employment costs and future profitability of the sponsoring employer.

There appear to be six alternatives a Company should consider and weigh up the alternatives of each, and if material necessary taking external advice, before making any irrevocable decisions.  There may even be others which have not yet been widely considered, such as sharing sponsorship of the Pension Scheme with another organisation, such as an asset manager.  I have not included them in the analysis.  To me the current alternatives appear to be:

  1. The company receives a taxable cash refund using a DB Pension Scheme past service “surplus”.
  2. The DB Pension Scheme runs on/out while the Company pays DC contributions in respect of its current employees.
  3. Using the “surplus” to pay DC contributions into a Master trust or a Group Personal Pension Plan.
  4. Using the “surplus” to pay contributions into a whole life CDC Scheme.
  5. Transferring Funds from a Pooled DB Fund to Individual DC Pots within the same Pension Trust Fund.
  6. Reopening or maintaining DB accrual within the same Pension Fund.

In the following article I set out my thoughts on the issues with each of these which an employer should consider when considering all the options available.  I am aware that not everyone will agree with all my points, and indeed I may have missed points others consider to be important.  I would welcome this feedback.

I have also discussed the alternatives available where there is a past service “surplus” reported in the pension scheme, but the same points apply when there is a deficit reported.  The key message is that at all stages all alternative courses of action should be considered against the current and future profitability and competitive position of the employer by including in the overall consideration alternative scenarios for current and future pension provision for its current and future workforce.

Where appropriate, I have repeated the same points across the alternatives.

Peter Cameron Brown BA(Econ) LlB FCA


1.    The company receives a cash refund using a DB Pension Scheme past service “Surplus” and pays DC contributions in respect of its current employees.

  1. Loss of Assets to a Tax Charge: The pension scheme has to deduct 25% tax on the amount refunded to the company.
  2. Share of Surplus with Previous Employees: The Trustees of the pension scheme have to agree an “equitable” distribution of the surplus between the company and its previous employees who are pensioners or have deferred benefits in the pension scheme; and determine the amount of surplus to be retained as a reserve in the pension scheme fund. These decisions are Trustee decisions over which the Company has no control.
  3. Effect on the Company’s Assets and Balance Sheet: Although increasing company cash by the net amount received, the company’s balance sheet and distributable reserves are reduced by

the loss to tax on the refund[1], plus

the reduction in the pension scheme asset from cash distributions to previous employees retaining benefits in the Scheme, and

the increased estimated valuation  cost of the enhanced future pension benefits of previous employees.

  1. Effect on Future Years’ Profitability: Future years’ profit and loss accounts will reflect the loss of the interest on full reduction in the pension scheme asset arising from the refund, the tax on it, and the benefit enhancements to the scheme members. The pension fund also loses the future investment return on the cash refunded to the company or paid out to the members.
    1. Administration Costs Incurred: The Company has to bear the future administration costs of the pension scheme, either by contribution or out of residual surplus. NB: these costs are capitalised and effectively prepaid as a lump sum in a buy-out bulk annuity transactions.
    2. Future freedoms: It is appropriate for the company to consider whether it wishes the pension scheme surplus to be refunded now or for it to remain invested by the pension scheme for possible alternative future uses for its benefit.
    3. On going Pension and Employment Costs: The Company’s DC contributions continue to be a cash outflow and a Profit and Loss charge.
    4. Future Risks: While at present the DC contributions may appear to be a fixed cost, the company has to consider the likelihood of future legislative changes and employment practices and whether they are likely to increase the cost to the company. Possible increases are likely to come from increased Government and employees, or their representatives, attention to the adequacy of pensions provided from DC pots – Pensions UK is lobbying for a minimum of 12% annual contributions and the Australian “Super” system, often cited as a good example, already mandates a 12% employer contribution.  An employer may also wish to reflect on the possibility of a loss of or restriction on the tax reliefs available, e.g., from the 2025 Budget proposed future restriction on NI relief on salary sacrifice arrangements.
    5. Employment Contract Restrictions: As part of the employment contract, DC contributions once set cannot be reduced without a formal renegotiation of the employment terms of current employees.
    6. Benefit Efficiency: For a targeted level of annual pension benefit, the combined contributions required from employers and employees is likely to be something like 50% more with DC than those required with a CDC or DB arrangement.
    7. Employee and Member Considerations: Cash payments to the DB scheme members in excess of benefits available to them under the Deed at time of service are treated when received as unauthorised payments and are currently taxed at 55%, but following the 2025 Budget proposals will be taxed at the Employee’s marginal rate, as at present applies to any discretionary benefits paid under the terms of the Deed. Enhancements to deferred benefits will count against the current year’s Annual Allowance and could trigger an Annual Allowance (tax) Charge on the Member.

Conclusions

Although there is an asset transfer from the pension fund to the company, the company cannot control the outcome and there are considerable leakage to taxes and also adverse effects on reported company strength and profitability.  The company is also committed to making future contributions into the DC pots of its current and future employees in accordance with employment terms and future legislative requirements. Members receiving enhanced benefits may suffer significant tax charges.


2.    The Pension Scheme runs on/out while the Company pays DC contributions in respect of its current employees

  1. Option considered: This is effectively a deferral of the cash refund option but the deferral of the reduction in the pension scheme asset allows the investment return on the scheme assets and the actual pension scheme experience to increase the assets available for ultimate refund.
  2. Loss of Assets to a Tax Charge: The loss to tax is deferred until the ultimate refund.
  3. Effect on the Company’s Assets and Balance Sheet: The Company’s Balance Sheet and distributable reserves reflect an increasing pension scheme asset. That asset being itself enhanced by investment returns in excess of the (low dependency) valuation assumptions and also actual pension scheme experience against valuation (mortality) assumptions.  The company may reasonably assume that in combination these are more likely to be positive than negative to the net asset value; and even if negative the effect is spread into the indefinite future.
  4. Effect on Future Years’ Profitability: The company retains a profit and loss credit on the total net assets of the Pension Scheme, while the company’s DC contributions continue to be a cash outflow and a Profit and Loss charge.
  5. Future Risks: While the present DC contributions may appear to be a fixed cost, the Company has to consider the likelihood of future legislative changes and employment practices and whether they are likely to increase the cost to the Company. Possible increases are likely to come from increased attention to the adequacy of pensions provided from DC pots – Pensions UK is lobbying for a minimum of 12% annual contributions and the Australian “Super” system, often cited as a good example, already mandates a 12% employer contribution.  An employer may also wish to reflect on the possibility of a loss of or restriction on the tax reliefs available, e.g., from the 2025 Budget proposed future restriction on NI relief of salary sacrifice arrangements.
  6. Employment Contract Restrictions: As part of the employment contract DC contributions once set cannot be reduced without a formal renegotiation of the employment terms of current employees.
  7. Benefit Efficiency: For a targeted level of annual pension benefit, the combined contributions required from employers and employees is likely to be something like 50% more with DC than those required with a CDC or DB arrangement.
  8. Timing of benefit sharing with Past Employees: The pension scheme Trustees are not required to consider the equitable distribution of a surplus between the company and the reducing cohort of past employees retaining benefits in the pension scheme until the time of the ultimate refund.
  9. Administration Costs Incurred: The Company has to bear the future administration costs of the pension scheme, either by contribution or out of residual surplus. NB: these costs are capitalised and effectively prepaid as a lump sum in a buy-out bulk annuity transactions (the capitalised cost should diminish over time in a closed scheme).
  10. Future freedoms: The company retains the flexibility to pursue other options, including the reopening of DB accrual within the same scheme (option 6 below), at any time in the future.

Conclusions

Although there is loss of a short term cash transfer to the company, the company is likely to benefit over the long term from the deferral of tax and the investment return on the pension scheme assets.  The company is able to control the timing of the Trustees’ consideration of the split of pension scheme surplus between a refund to the company and the enhancement to benefits of past employees.  Flexibility to switch to an alternative option in a possibly significantly changed future environment is retained.  However the Company is still subject to the restrictions associated with its contractual DC contributions and the transfer of assets out of the company’s domain, which includes the pension scheme, into the individual DC pots of its then current employees.


 

3.    Using the surplus to pay DC contributions into a Master trust or GPP:

  1. Loss of Assets to a Tax Charge: The pension scheme has to deduct 25% tax on the payments into employees’ DC pension pots as under present legislation and accounting rules they are treated as a refund to the employer from the pooled fund.
  2. Effect on Profitability: The company has to report the full cost of the company’s DC contributions funded in this way as a pension scheme cost in the Profit and Loss in the same way as if it had paid them in cash.
  3. Share of Surplus with Previous Employees: The Trustees of the pension scheme have to agree an “equitable” distribution of the surplus between the company to be used in this way and its previous employees who are pensioners or have deferred benefits in the pension scheme; and the amount to be retained as a reserve in the pooled pension scheme fund. These decisions are Trustee decisions over which the Company has no control.
  4. Effect on the Company’s Assets and Balance Sheet: Although increasing company cash by the net amount received, the company’s balance sheet and distributable reserves are reduced by

the loss to tax on the refund[2], plus

the reduction in the pension scheme asset from cash distributions to previous employees retaining benefits in the Scheme, and

the increased estimated valuation  cost of the enhanced future pension benefits of previous employees.

  1. Effect on Future Years’ Profitability: Future years’ profit and loss accounts will reflect the loss of the interest on full reduction in the pension scheme asset from the DC contributions paid, the tax on them, plus the benefits enhancements to the DB scheme members.
  2. Administration Costs Incurred: The company has to bear the future administration costs of the DB pension scheme, by contribution, or out of residual surplus, or by the capitalised cost in a buy-out transaction.
  3. Benefit Efficiency: For a targeted level of annual pension benefit, the combined contributions required from employers and employees is likely to be something like 50% more with DC than those required with a CDC or DB arrangement.
  4. Future Risks: While at present the DC contributions may appear to be a fixed cost, the company has to consider the likelihood of future legislative changes and whether they are likely to increase the cost to the company. Possible increases are likely to come from increased attention to the adequacy of pensions provided from DC pots – Pensions UK is lobbying for a minimum of 12% annual contributions and the Australian “Super” system often cited as a good example already mandates a 12% employer contribution.  An employer may also wish to reflect on the possibility of a loss or restriction on the tax reliefs available, e.g., from the 2025 Budget proposed future restriction on NI relief of salary sacrifice arrangements.
  5. Employment Contract Restrictions: As part of the employment contract DC contributions once set cannot be reduced without a formal renegotiation of the employment terms of current employees.
  6. Employee and Member Considerations: Cash payments to the DB scheme pensioners in excess of benefits available to them under the Deed at time of service are treated when received as unauthorised payments and are currently taxed at 55% but following the 2025 Budget proposals will be taxed at the Employee’s marginal rate, as at present applies to any discretionary benefits paid under the terms of the Deed. Enhancements to deferred benefits will count against the current year’s Annual Allowance and could trigger an Annual Allowance (tax) Charge on the Member.

Conclusions

Although there is a short term cash flow benefit to the company, the company cannot control the outcome and there are considerable losses to taxes and also adverse effects on reported company strength and profitability.  Over the longer term, the company is left with a fixed or increased cash outflow and Profit and Loss charge in the form of DC contributions. It is also highly inefficient in terms of the improvement in the DC members’ benefits for the amount of surplus being given up.

 


4.    Using the surplus to pay contributions into a whole life CDC Scheme:

  1. Loss of Assets to a Tax Charge: The pension scheme has to deduct 25% tax on the payments into the CDC Scheme as (at present) they are treated as a refund to the employer.
  2. Effect on Profitability: The Company has to report the full cost of the company’s CDC contributions funded in this way as a pension scheme cost in the Profit and Loss in the same way as if it had paid them in cash.
  3. Share of Surplus with Previous Employees: The Trustees of the pension scheme have to agree an “equitable” distribution of the surplus between the company and its previous employees who are pensioners or have deferred benefits in the pension scheme and the amount to be retained as a reserve in the pension scheme fund. This is entirely outwith the company’s control.
  4. Effect on the Company’s Assets and Balance Sheet: Although increasing company cash by the net amount received, the company’s balance sheet and distributable reserves are reduced by

the loss to tax on the refund[3], plus

the reduction in the pension scheme asset from cash distributions to previous employees retaining benefits in the Scheme, and

the increased estimated valuation  cost of the enhanced future pension benefits of previous employees.

  1. Effect on Future Years’ Profitability: Future years’ profit and loss accounts will reflect the loss of the interest on full reduction in the pension scheme asset from the CDC contributions paid, the tax on them, plus the benefit enhancements to the DB scheme members. The rate of employer contributions is a key design feature of the CDC scheme and are contractually fixed, but subject to any over-riding legislation.
  2. Administration Costs Incurred: The Company has to bear the future administration costs of the DB pension scheme, by contribution, or out of residual surplus, or by the capitalised cost in a buy-out transaction.
  3. Benefit Efficiency: For a targeted level of annual pension benefit, CDC should require 33% less total employer and employee contributions compared with a DC arrangement. As CDC scheme members, as opposed to DB scheme members, bear the administration costs of the CDC scheme, the benefit Efficiency of the contributions paid in is poorer than with DB, but better than with DC to a Mastertrust or a GPP arrangement.
  4. Employee and Member Considerations: Cash payments to the DB scheme members in excess of benefits available to them under the Deed at time of service are treated when received as unauthorised payments and are currently taxed at 55% but following the 2025 Budget proposals will be taxed at the Employee’s marginal rate, as at present applies to any discretionary benefits paid under the terms of the Deed. Enhancements to deferred benefits will count against the current year’s Annual Allowance and could trigger an Annual Allowance (tax) Charge on the Member.

 

Conclusions

Although there may be a short term cash flow benefit to the company, the company cannot control the outcome and there are considerable losses to taxes and reported company strength and profitability.  Over the longer term, the company is left with a fixed or increased cash outflow and Profit and Loss charge in the form of contractually fixed CDC contributions. It is however more efficient in terms of the improvement in current employees’ retirement income for the amount of surplus being given up than a transfer to individual DC pots.

 


5.    Transferring Funds from the Pooled DB Fund to Individual DC Pots within the same Pension Trust Fund

  1. Loss of Assets to a Tax Charge: As there is no real or notional refund to the employer, the pension scheme does not have to levy a refund tax charge.
  2. Availability of this option: This will only be possible if the power to transfer from the pooled fund into the notional DC pots of individual members is permitted within the Trust Deed. Such a Deed is likely to specify the situations in which this will be possible.
  3. Possibility of change: It is unlikely a new DC section could be introduced into an existing DB Trust which allows the existing pooled DB fund partly funded by members’ contributions to be transferred into the individual notional DC pots of employees who were not also members in the DB fund. The precedent case (Standard Life) where the permission of the Courts was obtained to amend the Deed to permit a DB pool to be used for DC benefits recognised that the donor DB scheme had been almost entirely employer funded.  In any event, it is likely that considerable legal costs will be incurred in pursuing this option.
  4. Share of Surplus with Previous Employees: The Trustees of the pension scheme have to agree the amount to be retained as a reserve in the pooled DB fund and an “equitable” and Deed permitted distribution of the surplus between enhancing the benefits the previous employees who are pensioners or have deferred benefits in the DB section and increasing the individual DC pots in the DC section. This is entirely outwith the company’s control.
  5. Effect on the Company’s Assets and Balance Sheet: The company’s Balance Sheet and distributable reserves are reduced by the full amount of the transfer from the pooled fund into the individual employees’ DC pots.
  6. Effect on the Company’s P&L A/c in the transfer years: The P&L A/c will reflect as a charge the full amount of the contributions out of the pooled fund into the individual DC pots even though there was no cash flowing from the company.
  7. Effect on Future Years’ Profitability: Future years’ Profit and Loss will reflect the loss of the interest on full reduction in the pooled pension scheme asset from the transfer into the individual employees’ DC pots and also by DC contributions fixed or increased by employment contracts or legislation.
  8. Employee and Member Considerations: The transfer into the Members’ individual DC pots will be treated as a pension contribution during the year subject to the Annual Allowance is the same way as they had been contributed by the company.
  9. Administration Costs Incurred: The company has to bear the future administration costs of both the DB and the money purchase sections, either by annual contribution, or out of residual surplus in the DB asset pool, or by meeting the capitalised cost in a DB benefit buy-out transaction.

Conclusions

Although there is a short term cash flow benefit to the company and no loss to tax, over the longer term, the company is left with a fixed or increased cash outflow commitment and P&L A/c charge in the form of future DC contributions and the loss of investment return from a decreased asset base in the pooled fund. It is however more efficient in terms of the improvement in current employees’ retirement income for the amount of surplus being given up than a transfer to individual DC pots resulting from pooling the investments and no forced sale of assets.


6.    Reopening or maintaining DB accrual within the same Pension Fund

  1. Availability of this option: Apart from the mandatory employee consultation, an employer is entirely free to introduce a new section of DB benefits for future service into an existing DB pension fund. The benefits need not reflect those previously provided by the Scheme.
  2. Effect on the Company’s Assets and Balance Sheet: The entire pool of scheme assets including those contributed by both the company and employees in respect of both past and current service are available to fund all the benefits accrued. The capacity to fund the benefits of the historic section from current contributions gives significant investment freedoms not available to a closed scheme and thereby reducing the future cost to the employer under the balance of cost arrangement.
  3. Effect on Valuation Surpluses or Deficits: The scheme will be regarded as a single entity for valuation purposes. This will progressively push forward the “significant maturity” date (subject to employer’s longevity covenant).  This will provide considerable protection against short term market risks affecting either asset values or the liability valuation assumptions.
  4. Loss of Assets to a Tax Charge: There is no loss to tax as no surplus is being refunded to the company.
  5. Share of Surplus with Previous Employees: The Trust Deed instructions to Trustees remain under the control of the company. Trustees are not required to consider a shared distribution of surplus between the company and pension scheme members who were previously in pensionable service with the company or its predecessors. (Although in Equity, Trustees may wish to consider using existing discretionary powers under the Deed to maintain real values of pension benefits before agreeing a Schedule of Contributions with a full or partial employer contribution holiday)
  6. Future freedoms: Under the balance of cost arrangement, the surplus can be returned to the company through reduced future employer contributions. There are no minimum contributions set for DB schemes under the auto-enrolment regulations (there is a minimum benefit accrual rate of 1/120th of “qualifying earnings”).
  7. Effect on Future Years’ Profitability: The company’s Profit and Loss will reflect the current service cost of the current DB benefit accrual (calculated using the opening AA bond yield) offset by an interest credit on the opening surplus (calculated using the same basis). With realistically stronger investment performance than the valuation assumption, it is therefore quite feasible for the net pension cost to become negative and the pension fund to be a contributor to company profitability.
  8. Competitive Considerations: The cash flow and reported profitability advantages should give the company providing DB accrual a competitive advantage against competitors who are providing DC pension benefits. This would be particularly marked against competitors who are following a high cost buy-out strategy for their pension scheme.
  9. Employer Covenant Considerations: Provided the current service cost is being fully funded, the employer’s covenant towards the pension scheme should be enhanced by the continuing accrual of DB benefits.
  10. Administration Costs Incurred: The company has to bear the future administration costs of the pension scheme, either by payment, or out of surplus in the total asset pool. However these costs are relatively fixed with regard to the increasing number of members in the scheme and total asset values.
  11. Recruitment and Retention Benefits: There are the recruitment and retention benefits of an employer providing a “gold plated” DB pension promise. The current employees have a guaranteed pension in retirement, protected by the PPF, without the uncertainty and potential stresses of a DC arrangement. Given that the employer directly or indirectly funds the administration costs, the value for money of the employee and employer contributions should be greater than that provided by a CDC arrangement, itself significantly greater than that provided by the equivalent contributions into a DC arrangement. As the employer defines the pension terms for its employees, there is no need to consider inter-personal “fairness” associated with a wealth generating pension savings vehicle.

 

Conclusions

Compared with the other alternatives, it does appear that providing DB accrual to current employees may be the most cost effective and lowest risk alternative for an employer with an existing DB scheme in surplus (and also potentially for employers whose pensions scheme is not yet fully funded).

 


The Taxpayer’s Point of View

This paper is written from a company point of view with reference to a “loss to tax” where relevant.  This does not necessarily mean that there is a cost to other tax payers when measured over the longer term:

If a company with a DB pension scheme in surplus uses that surplus to fund further pension accrual, the Exchequer gains from the unused tax relief on the future contributions which otherwise would be paid.  This results in increased Corporation Tax paid by the Company and the Income tax and National Insurance Contributions paid by the Employee respectively. The taxes at issue are 25% on company contributions, 20%, 40%, or possibly 55% marginal rate on employee contributions plus employee National Insurance at 8% or 2%, plus in some circumstances 15% Employer NI.


General Conclusion

It is important that advisors should fully explore all options with employers, whether or not the employer has already commenced a strategy designed to achieve an eventual buy-out.  A failure to do this is likely to lead to a further degradation of the UK industrial and commercial base.

 


Details

[1] Balance Sheet totals may reflect a release of a previous provision for deferred taxation to the extent that it is no longer required.

[2] Balance Sheet totals may reflect a release of a previous provision for deferred taxation to the extent that it is no longer required.

[3] Balance Sheet totals may reflect a release of a previous provision for deferred taxation to the extent that it is no longer required.

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