The crazy world of freedom from pensions evolved as John Mather describes. I agree with this as a factual explanation of how we got to where we are now. – ed (Henry Tapper)
John Mather’s explanation of how we’ve moved away from pensions has authenticity, he was born soon after the war and has a longer memory than most now in their seventies. There are others- I know my readership includes half a dozen!
John Mather’s comment on pensions for the wealthy
John Mather
The U.K. pension system generally follows an EET (Exempt, Exempt, Taxed) model: contributions are exempt from tax, investment growth is exempt, but withdrawals (income) are taxed.
The last 30 years have seen this model shift from a relatively “wild west” era of high limits to a highly restrictive regime, and most recently, a significant liberalization under the “Pension Freedoms.”
So while saying invest for the long term is destroyed by the legislation that punishes the lower liquidity and long term nature of successful infrastructure investment.
Key Changes to the Pension Tax Model (1996–2026)
The Pre-A-Day Era (1996–2006)
Before April 2006, the system was fragmented with different rules for “occupational” vs. “personal” pensions.
• Earnings Caps: Rigid limits on how much of your salary could be considered “pensionable” (often capped around £100,000).
• The Dividend Tax Blow (1997): One of the biggest shifts in the “Exempt” growth phase. Chancellor Gordon Brown abolished the ability for pension funds to reclaim tax credits on UK dividends, effectively removing billions in “exempt” growth value from pension pots over the following decades.
2. “A-Day” Simplification (April 2006)
The government replaced eight different tax regimes with a single unified framework.
• Introduction of the Lifetime Allowance (LTA): A total cap on how much you could save over your life without a 55% tax charge. It started at £1.5 million.
• Introduction of the Annual Allowance (AA): A cap on yearly contributions, initially set at £215,000.
• 25% Tax-Free Lump Sum: Codified the “Exempt” part of the withdrawal phase, allowing 25% of the pot to be taken tax-free.
3. The “Squeeze” Era (2010–2022)
As the government sought to reduce the deficit, the “Exempt” portions of the model were aggressively scaled back.
• Annual Allowance Cuts: The yearly limit was slashed from £255,000 (in 2010) down to £40,000 (by 2014).
• Lifetime Allowance Cuts: The LTA peaked at £1.8 million in 2011 before being cut multiple times down to a low of £1 million in 2016 (later indexed slightly to £1.073m).
• Tapered Annual Allowance (2016): Introduced a “sliding scale” for high earners, reducing their annual tax-free contribution limit to as little as £4,000 if their income exceeded certain thresholds.
4. Pension Freedoms (2015)
This changed the “Taxed” part of the model.
• Removal of Compulsory Annuities: Previously, most people were forced to buy an annuity (taxed income). After 2015, savers could withdraw their whole pot as a “lump sum” (though anything above 25% is taxed at their marginal income tax rate).
• Death Benefits: If you die before 75, your heirs can often inherit the pension tax-free (the ultimate “Exempt” loophole). If you die after 75, they pay their marginal tax rate.
5. The Radical Liberalization (2023–2024)
In a surprise move to keep older professionals (like NHS doctors) in the workforce, the government reversed many “Squeeze” era restrictions.
• Abolition of the Lifetime Allowance (2024): The LTA was completely removed. There is now no limit on how much you can grow your pension pot without a penalty tax.
• Annual Allowance Increase: The yearly contribution limit was raised from £40,000 back up to £60,000.
• Lump Sum Allowance (LSA): While the LTA is gone, the “tax-free” portion was capped at £268,275 (25% of the old LTA), ensuring the “Exempt” withdrawal part doesn’t grow infinitely for the ultra-wealthy.
John concludes (in comments)
My point is a simple one: if the trend is towards being less appealing to the audience required for illiquid investing, add the regulatory requirement for sophisticated HNW qualifications, and more contradictory objectives result.
The goalposts are not just moved but removed. This produces a game with no objectives, just a way to administer the funds so that they can pay invoices.
Here is the full force of the Conservative parties (and allies) railing against the reserve powers of Government to ensure pensions keep on the target of the Mansion House Accord. Is this really worth the excitement?
There’s a lot of posturing here from people who have no better things to do.
The link to Tom McPhail’s article puts Tom in line to be a Conservative shadow pension minister, if the Conservatives make it to opposition at the next election.
History tells us this pensions plot will cost us dearly
There are 22 million people putting their hard-earned money into a workplace pension — and they don’t need the government telling them where it should be invested
There is a battle being waged over the control of the UK’s pension savings, affecting the retirement pots of 22 million people saving into a workplace pension scheme.
The government is trying to push through legislation (the Pension Schemes Bill) which, among other things, would give it the power to direct pension scheme trustees over how they invest members’ savings. It would enable the government to force investment into the UK and into specific types of project, selected by the government in aid of its agenda for economic growth.
The leading pension trade bodies, the Association of British Insurers and Pensions UK, have both written to the pensions minister Torsten Bell politely suggesting he should back off. They have pointed out that there already exists a voluntary scheme whereby pensions will invest in UK growth projects, but only where trustees believe it is in the interests of members.
The Conservative shadow pensions secretary Helen Whately is also campaigning against this state interference.
The pensions minister Torsten Bell is under pressure over proposed government control of workplace pension investments
It’s not just the obvious problem that once you override pension trustees’ fiduciary duty to do the best they can for their members, you have crossed the Rubicon. You’re in territory where distorted priorities lead to lower pension investment returns in pursuit of political ideology.
Adve
There’s also the fact that you’re directly interfering in the mechanism that has transformed the standard of living of billions of people, including pretty much everyone born in this country over the past 250 years.
It’s not just the present government we need to worry about. How would you feel if Zack Polanski became prime minister and had the power to dictate where your pension savings were invested?
Lawmakers are seeking greater control over how retirement funds are invested
It is easy to forget that between the end of the Roman Empire and the late 18th century the standard of living in this country barely rose at all. Then something miraculous happened. The industrial revolution was born of the growth of free trade.
The ability of individuals and businesses to freely trade goods and services, entering into transactions of mutual benefit, is what has delivered the prosperity we enjoy today. It led to the economic growth that has made us all better off.
Economics is about the employment of scarce resources that have competing uses. It is the free market and the millions of daily transactional decisions the free market entails, entered into for the benefit of all involved, that determines how resources can be best employed.
The result is the extraordinary economic flourishing that today underpins and pays for the public services and the standard of living we all enjoy. This only works, though, if you don’t interfere.
Industry voices warn that interfering with trustees could have long-term consequences
Every time a politician or regulator imposes a price cap, a wage or rent control, or directs capital in a particular way, the result is lost economic growth. This is not to say that we don’t need any regulations, but they should be kept to an absolute minimum and we certainly don’t need some cocksure pensions minister giving himself the powers to dictate where our pension funds are invested.
He should heed the warnings of the pensions industry and the political opposition and think again, for all our sakes.
The Bill looks more than likely to be enacted in May.
I don’t understand much about this but with the people who are on the other side of the coffee morning on Tuesday, I know it will be fun, stimulating and well worth attending!
Please join us for our next Coffee Morning event …..Risk – to be or not to be.
The UK is moving to a largely DC pension system (and potentially CDC). Ideally, in DC, the investment/decumulation options reflect the risk preferences of citizens, but the industry has a tendency to offer “one-size-fits-all” solutions or “lifecycle funds” that fit nobody.
This session will explore the results of a risk preference survey conducted by Professor Narmin Nahidi of Exeter University.
Dr Narmin Nahidi is an Assistant Professor of Finance at the University of Exeter, where she teaches across finance topics with a focus on degree apprenticeships. With over two decades of combined experience in academia and industry, her research explores the intersection of corporate finance, financial technology (FinTech), and behavioral finance increasingly extending into issues of sustainability, ESG accountability, and climate risk in financial systems.
Narmin’s work has been published in peer-reviewed journals and presented at international conferences. She holds a Ph.D. in Finance from Università Ca’ Foscari Venezia, is a Senior Fellow of the Higher Education Academy (SFHEA), and a Certified Management & Business Educator (CMBE). She is passionate about equipping future finance professionals with the tools to navigate a rapidly evolving and sustainability-conscious global economy.
Narmin will be joined by Arun Muralidhar and Sid Muralidhar and they will discuss their findings on whether risk preferences differ based on age, gender, education, occupation, religion or even geography.
These results could help improve regulation, product design, innovation for greater retirement security.
If you could please take this anonymous survey (before the event) and share it with friends and family (ideally those not in the pension/financial services industry), it would help them make a fun presentation to the group.
When people say “real” income, they mean income that keeps pace with inflation. Real income is a fantastic promise to make to someone retiring.
Those under 55 today are a generation for whom “stagflation” is no fear, they underestimate how hard it has been to keep pace with inflation at times over the past 80 years.
Stagflation is a combination of high inflation, low economic growth and flat or decreasing prices for investable assets.
During the 25 years when I was young (1961 -1986 ), inflation and interest rates were at a rate that many of us wondered if we’d have pensions. We thought we would be undone by inflation that regularly topped 10% and sometimes 20%. Inflation was the great worry to my generation going into work.
Yet somehow , the first workplace pensions came out of those difficult years and did so because despite the problems of high inflation and volatile markets, funded pensions that started to embrace long term real assets like equities and property.
The damage then of “stagflation” to the economy is somewhere in the back of my head and I don’t underestimate living at a time when inflation is targeted to be no more than 2 or 3%.
It’s not just the damage to the economy as the damage that those years created in society. The strikes and the industrial warfare were as a result of this economic mismanagement and the economy is now being managed better. The one thing that has been consistent over the course of my lifetime has been investment over time in real assets, it is the basis of CDC.
I do not write as an economist, I never did economics at school nor studied it at college , but I knew that inflation and the high interest rates it brought meant financial planning involved having faith that investing in real assets would eventually deliver financial comfort, it eventually did.
We are in a fortunate position to run pensions , whether that position is in the DWP and GAD – running the state pension or in the private sector as trustees , insurers and consultants. I read with pleasure this morning this paper by consultants LCP which confirmed that we are now returning to sanity on pensions , investing in real assets to beat inflation and delivering pensions to ordinary people (like me) who have a distant memory of losing to inflation.
The paper accompanying the modelling accepts that the biggest threat to our pensions is stagflation, it points out that nothing can overcome high inflation and no growth in the economy or asset prices.
But it argues that taking a long term view, as this country did when I was young, is the way to win through. CDC is the way for us to invest for those who will be alive in the 22nd century!
New modelling of how CDC schemes would have fared over the last 80 years shows well-designed CDC schemes prove resilient to radically different market conditions.
The analysis by LCP which uses actual historic returns and market conditions to model outcomes from different types of pension arrangements over time, highlights that over three out of the four time periods, the CDC pensioner ended the 20-year period with a pension that beat inflation. Only over the extreme stagflation regime of 1963–1983 was there a material real loss.
The modelling has led to four findings:
CDC remains resilient across very different market environments – LCP’s modelling shows CDC delivers consistently stronger and more stable outcomes than individual DC across all four historic economic regimes modelled, outperforming inflation in three out of four 20 year periods. CDC smooths volatility by avoiding “point in time” losses at retirement, from a member perspective sitting between DC and DB in terms of risk and stability.
Growth asset exposure drives CDC’s long term outcomes – CDC’s ability to maintain exposure to growth assets throughout retirement – unlike DC annuity purchase – underpins its resilience. Strong markets feed directly into higher pensions, while downturns do not permanently lock in lower outcomes.
Outcomes vary by age and horizon – Younger members see stronger outcomes because they can benefit from “cheap accrual” during weaker market periods and have longer to recover from volatility. Older members have some protection of short-term pension purchasing power, with outcomes shaped by how increases and accrual costs shift year to year.
CDC adjusts pensions over time rather than locking in outcomes – CDC pensions evolve with market conditions: they rise in strong markets and fall behind inflation in challenging periods, but avoid the large nominal cuts typical in some other designs. This flexibility reduces the risk of poor retirement timing and allows pensions to recover when conditions improve.
“Our analysis highlights how different pension designs respond to very different economic environments. CDC does not eliminate investment risk, nor does it guarantee outcomes. Instead, it changes how risk is shared and how outcomes adjust over time.
“The experience of the past 80 years does not predict the future, but it does illustrate the structural strengths and limitations of different pension designs. For policymakers, trustees, and employers considering CDC, the key question is not whether risk can be removed, but how it should be shared — and whether members are comfortable with the form that sharing takes.”
“One of the key strengths of CDC schemes is that they avoid locking in poor outcomes at a single point in time, allowing members to continue participating in long-term growth during retirement. Compared with purely individual arrangements, it spreads the impact of adverse market conditions across members and over time, reducing the severity of poor timing for any one cohort.
“These features come with trade-offs. Outcomes within CDC vary by age and market experience, and pensions in payment may fluctuate in real terms. Whether this is viewed as desirable depends on how fairness is defined: as individual ownership of outcomes, or as collective sharing of risk.”
There is nothing new about CDC, it would have succeeded for 80 years in the model created by LCP. It is important that we think of it as the basis of our of private retirement planning for the next 80 years and longer.
I don’t understand much about this but with the people who are on the other side of the coffee morning on Tuesday, I know it will be fun, stimulating and well worth attending!
Nahim Nahidi
Please join us for our next Coffee Morning event …..Risk – to be or not to be.
The UK is moving to a largely DC pension system (and potentially CDC). Ideally, in DC, the investment/decumulation options reflect the risk preferences of citizens, but the industry has a tendency to offer “one-size-fits-all” solutions or “lifecycle funds” that fit nobody.
This session will explore the results of a risk preference survey conducted by Professor Narmin Nahidi of Exeter University.
Dr Narmin Nahidi is an Assistant Professor of Finance at the University of Exeter, where she teaches across finance topics with a focus on degree apprenticeships. With over two decades of combined experience in academia and industry, her research explores the intersection of corporate finance, financial technology (FinTech), and behavioral finance increasingly extending into issues of sustainability, ESG accountability, and climate risk in financial systems.
Narmin’s work has been published in peer-reviewed journals and presented at international conferences. She holds a Ph.D. in Finance from Università Ca’ Foscari Venezia, is a Senior Fellow of the Higher Education Academy (SFHEA), and a Certified Management & Business Educator (CMBE). She is passionate about equipping future finance professionals with the tools to navigate a rapidly evolving and sustainability-conscious global economy.
Narmin will be joined by Arun Muralidhar and Sid Muralidhar and they will discuss their findings on whether risk preferences differ based on age, gender, education, occupation, religion or even geography.
These results could help improve regulation, product design, innovation for greater retirement security.
If you could please take this anonymous survey (before the event) and share it with friends and family (ideally those not in the pension/financial services industry), it would help them make a fun presentation to the group.
Does this sound familiar? It is of course the problem with selling obscure funds to those who consider the “wealth adviser” is acting for themselves not for the financial institutions they work for.
As yet the likes of Apollo and Blackstone aren’t household names in the UK (as they are in the USA) but if they get caught out for mis-selling private market funds, be pretty sure we will know it. It only needs one of these names to do what happened to Lehman and the covenant behind the insurers we recognise, will put the likes of PIC and Just in jeopardy.
Here is the email I get from FT every morning, this morning it’s like winding back the calendar nearly 20 years to when American banks and finance houses were last making news over here.
Wealth advisers at banks and independent brokerages generated billions of dollars in fees by steering individual investors into private market funds, which many retail investors are now trying to flee, write Antoine Gara, Amelia Pollard, Eric Platt and Harriet Clarfelt.
Sixteen funds, including those managed by Blackstone, Blue Owl, Apollo and KKR, have produced more than $2bn in servicing fees for wealth advisers since 2017 even before lucrative upfront commissions, according to an FT analysis of regulatory filings.
The data show how big banks such as Morgan Stanley, UBS and Bank of America Merrill Lynch and other independent wealth managers benefited from the boom in private funds targeting individual investors before it started to sour last year.
Semi-liquid or “evergreen” vehicles, which allow investors to deposit and withdraw money at set intervals, soared in popularity over the past five years as a long bull run helped expand the ranks of wealthy individuals seeking to diversify their assets.
They also proliferated as a source of predictable and lucrative fees for both private capital firms and wealth advisers.
Some of those funds have turned to net outflows in recent months amid concerns about asset valuations and underwriting standards, with investors seeking to withdraw more than €20bn from private credit vehicles in the first quarter of the year.
As scrutiny of private credit has intensified, some on Wall Street have pointed blame at incentive structures that herded rich investors towards these products as contributing to the asset class’s rapid growth.
Banks told the FT that their wealth advisers are bound by a fiduciary interest to steer clients to appropriate investments, and were not incentivised by fees. Morgan Stanley said it was often able to “negotiate aggressively” on behalf of clients, leading to lower total fees.
“Of course they’re incentivised by these fees” said Bob Elliott, the founder of Unlimited Funds, referring to advisers at big brokerages, also known as wirehouses.
“Any person who has a wirehouse adviser knows that they’re constantly being pushed products that are financially [beneficial] for either the adviser or the wirehouse, or both.”
I am not so worried by the impact on our wealth industry which is less likely to move to “wirehouse” tactics. But Morningstar offers Pitchbook to sophisticated investors and advisors in this country.
I think a more dangerous consequence of the failure of funds such as Blue Owl will have consequences for private equity firms who own our insurance companies that own the money that was in our pension funds.
Private equity is the security that pensioners have where they once had gilts. Private credit is controlled by the organisations that have bought out our pensions. Private credit is in trouble not just for being mis-sold but because many of its evergreen funds are locking investors in – the wealthy in the UK remember the Woodford feeling.
In case you’re confused – the £100k of tax @TiceRichard failed to pay here is totally different to the
– £92k of tax not properly withheld on dividends
– the £600k side-stepped via highly aggressive tax avoidance
Industrial scale grifting revealed by @Gabriel_Pogrundhttps://t.co/EekZnYapAE
He has dismissed all scrutiny of his affairs, describing a previous investigation by this newspaper into his “aggressive”, but apparently legal, tax avoidance as an attack on a “successful businessman”. He dismissed subsequent evidence he failed to pay tens of thousands in tax as a “technicality”.
On Saturday night, after declining to respond to our inquiries, Tice published a statement addressing his wider tax affairs. He said: “Naturally I am always happy to put things right and if numbers need rechecking, of course I will pay what is owed — be that more or less”. He accused The Sunday Times of unspecified “assumptions, numbers and dates” that were “incorrect”. He said he would no longer be “indulging” the newspaper and claimed our reporting constituted part of a “smear campaign”. He did not dispute or challenge any specific part of our reporting.
The latest developments also pose questions for Farage, who turned to Tice to run and bankroll Reform between the 2019 and 2024 elections when he considered retiring. During the period in question, Tice served as either leader or chairman.
Farage defended Tice last week and was accused of “snapping” at a reporter who asked him to provide evidence for his deputy’s claim that HMRC was not left out of pocket. The Reform leader would not do so and referred to the complexity of tax rules.
The latest disclosures relate to four companies run by Tice and registered an address in Berkeley Square, Mayfair, all of which are required to file publicly available accounts. Tisun 1, Tisun 2 and Tisun 3, were formed on the same day in July 2018. Tisun 4 was created two years later. In official filings, all describe the “nature” of their business as that of a “dormant company”. Records suggest their sole role was to receive payments from Quidnet in which they held shares. Quidnet rents out eight nondescript industrial estates it owns from Newark and Northampton to Wigan. Its biggest premises is a 159,000 sq ft site in Darlington, once used by British Steel.
This is all about corporate tax but Torsten Bell has picked up on the personal aspect of this
The accounts state that Tice wrote off the whole “expected” tax bill of each Tisun entity, leading to a bill of zero. According to the analysis of several professionals we consulted, he should have instead taxed the payments, totalling £517,694, at the normal rate of corporation tax, then 19 per cent, leading to a bill of £98,362.
Tice offered two different explanations for why he did not pay tax on the profits when first asked by this newspaper some weeks ago.
One was that Tisun Investments, the parent group of Tisuns 1-4, made overall losses, meaning by law the subsidiaries did not need to pay tax. Tice said over WhatsApp: “[Tisun] had losses overall … so tax is paid/offset in the group.” He added that “the accountants will have applied the group taxation rules fully” and that any due tax would have been paid at “the group level”.
Neidle was one of several specialists who examined this argument. He, like the others, concluded it was not a viable theory: the parent group had not suffered the kind or scale of losses required for Tice to have written off the tax bill of each entity each year. In addition, there was no reference to parent losses in any of the relevant accounts, which, according to Neidle, there ordinarily would be if this applied.
This is the industrial scale grifting referred to by the pension minister Torsten Bell
The other reason Tice put forward is that “companies don’t usually pay tax on divis [dividends] from other UK companies”. While this argument is not legally correct in the circumstances — these were taxable PIDs, not tax-free normal dividends — it does tally with the story presented in the accounts. These explicitly state that he paid no tax by attributing 100 per cent of profits to non-taxable “dividend income”. But they go further still.
The accounts can also be downloaded in a machine-readable format called iXBRL. This includes information invisible to the human eye, but “visible” to computers, for each piece of text. In this scenario, we can specifically see that Tice, or someone working for him, used accounting software to generate his accounts and reduced his tax bill by inserting his profits into a box marked “dividend income”. This generated an invisible tag referring to the “effect [of] dividends”.
Tice with Farage and other Reform members at the party conference in September
It is a criminal offence for a director to “recklessly” provide false information on company accounts. Tice as sole director was responsible for submitting returns and filing accounts.
Over the years in which tax was not paid — 2020 to 2022 — Tisuns 1-4 passed their profits to Tisun Investments Ltd, which, via a holding company, Tisun Holdco Ltd, is owned by Tice. According to the Electoral Commission, during the same period, Tisun Investments loaned £1.113 million to Reform in 36 payments. Several of the loans (worth a combined £350,000) were converted into gifts years later.
Neidle said there was no ambiguity about the rate at which the payments to Tisuns 1-4 should have been taxed. He said: “This is a basic rule, not a grey area, and one widely understood across the industry.” He pointed to the fact that Tice himself had made the unusual decision to convert Quidnet into a real-estate investment company, a tax-efficient legal status whose key feature is that profits are paid out as PIDs, not ordinary dividends. Quidnet even referred to “PIDs” in the company’s accounts and stock market announcements.
If this is what Tice calls “being good at making money” then I hope we hold him in the same regard as we do one American politician.
Neidle said: “The fact the difference was missed repeatedly, across multiple companies and years, raises obvious questions.”
Tice, his lawyer and Reform did not respond to our inquiries. Several weeks ago Tice told us that “no questions have been asked by HMRC so I trust them more than whoever is advising you”.
The story of Tice’s complex tax affairs begins in September 2018. He was becoming increasingly involved in eurosceptic politics and would be appointed as chairman of the Brexit Party, the forerunner to Reform, founded by his friend Farage, within weeks.
Still, he had no intention of leaving the property world he had worked in since his twenties — and which had made him his first millions. He had particularly big ambitions for the company he had created a few years earlier.
On the face of it, Quidnet was an unglamorous collection of industrial estates and business parks in Newark, Northampton and West Sussex. Its properties were worth £12 million, small fry compared with the investments he had managed firstly as chief executive of his grandfather’s property group, which he ran from the age of 27, and later as chief executive of CLS Holdings Plc, a FTSE-250 listed company.
But Tice wanted to take Quidnet’s activity to the next level. That September, having already taken the required first step of listing it on the Guernsey stock exchange, he applied for it to become a real-estate investment trust (REIT). REITs tend to manage billions of pounds of property — British Land Plc is one well-known example — and are designed to widen access to commercial property for retail investors. The company pays out profits on a regular basis, with shareholders, not the company itself, left to pay any resulting tax. As Tice himself reported in that year’s accounts, the structure is “attractive for those seeking high income in a tax efficient manner”.
The status was not, however, designed for companies like his. His was not just a modestly sized firm, but, critically, one more or less wholly owned by him via a collection of mostly tax-efficient entities: an offshore trust, a pension investment trust, the newly created shell companies Tisuns 1, 2 and 3, and latterly Tisun 4. In fact, the rules actually exclude companies like his from acquiring the status — they have to be owned by lots of people, or be “open”, not “close”, as the law defines it.
Yet Tice was able to benefit from a loophole. Quidnet had a three-year grace period — starting then, in September 2018, and ending in September 2021 — in which it could find new investors in order to meet the conditions for permanent existence as a REIT.
Tice did not use the time as intended. He never secured anything like the number of outside investors required. In fact there is no evidence he shared investor materials publicly and when we asked for a copy of such information, he declined, citing “confidentiality”. While Tice brought on board some colleagues as small shareholders, and an investor operating via the Channel Islands, he always owned more than 90 per cent of the company and so was forced to forfeit the status after two years and 11 months.
Yet in the meantime, his company enjoyed all the tax-perks of REIT status, and did not have to pay a penny in corporate tax on its profits. That amounted to a saving of £600,000. Tice’s shareholder structure made him further savings. One requirement of REITs — even those in the “grace period” — is that they regularly shell out profits in payments to shareholders. Tice was, for all intents and purposes, the owner of the company but he did not own all of its shares personally. If he had, he would have paid income tax on any payments, but, instead, several of the entities that owned slices of the pie on his behalf were not required to pay any tax at all due to their status.
When The Sunday Times first revealed his unusual company structure last month, Neidle, the tax expert, said the arrangement looked “aggressive”.
Tice said there was no problem. He avoided tax, did not evade it, and had done nothing wrong, he claimed. To such criticism, Tice had a simple narrative. He said the story was a “smear”. He said Neidle, whose investigations have covered Keir Starmer and Angela Rayner as well as Nadhim Zahawi, was biased in favour of Labour. He opened a Reform conference in Westminster on March 16 by selectively quoting from The Sunday Times’s output the previous day and, when asked if Britons should avoid as much tax as legally possible, said “yes”.
The tenor of the conversation changed last Sunday, however, when this newspaper further reported that, for all the legitimate, and apparently legal, tax perks of its status, Quidnet had actually broken the law. One thing REITs are required to do is deduct a certain amount of tax before making payments to certain kinds of shareholders. But Tice did not do this. HMRC was left at least £91,000 out of pocket as some investors received payments that were far too large. This time, Tice described it as a “tax technicality” and offered a political, rather than legal argument: he claimed that by overpaying himself, he had ended up paying more income tax, meaning the taxman eventually received the same sum anyway. When asked to give evidence of this, he refused. In addition, there is no legal way for a company to write off its tax bill simply because another party has paid more tax as a result of the company’s previous non-payment.
The day after that story was published, Farage was asked about the failure and responded abruptly, telling a reporter to give him a “lecture” on the nature of REITs.
Today’s disclosures reveal Tice repeatedly signed off accounts describing the payments made to Tisuns 1-4 as something specialists say they were not — ordinary dividends — when they could only have been PIDs, meaning tax should have been paid. Over several years, the accounts, which were personally signed off by the Reform deputy leader, include a line for the “expected” tax bill — the amount the company should have paid — followed by a section headed “dividend income”, which shows the profits for the previous year being deducted from the bill. By the following line, the “actual” tax bill is zero. Last week Tice refused to respond to analysis indicating that, in fact, every penny should have been taxed at the normal rate of corporation tax.
To a layperson, accounts are difficult to comprehend and often include complex accounting jargon. But, thanks to a feature of modern accounting, we are able to confirm that Tice did indeed state that the tax could be written off as tax-free dividends. Since 2011, all UK companies have been required to submit accounts to Companies House, the UK’s official government registrar of companies, in a format known as iXBRL, which means they can be read by a computer as well as humans. Such data is published and is available to the public.
The iXBRL files for the Tisun companies show that Tice, as director, completed his accounts using CCH, a piece of software run by Wolters Kluwer, a Dutch firm. It also lets us see exactly what steps Tice, or his accountant, took when using the software to generate certain sections. In particular, we can see that the Tisun entities filled in the tax section by reporting the amount of money received in property income distributions (PIDs) as dividends instead — and inserted the total payments received into a section called “dividend income”.
This human act led to the generation of an invisible tag — Tax Increase Decrease From Effect Dividends From Companies — which means the tax bill has fallen because of the effect of dividends being taken into account. Adam Mohamed, of the Financial Reporting Council, confirms the code generated represents “the adjustment to the total tax charge caused by dividends received from companies being taxed at a different rate than the [normal] rate”.
During the period in question, Tisuns 1-4 transferred their profits to their parent group, Tisun Investments Ltd. During the Brexit Party’s transition to Reform UK, the limited company was one of Farage’s largest funders, making several dozen loans worth more than £1 million and later converting them to the gifts.
Without the money, Reform would have been deprived of one of its biggest sources of income at a time when it was recovering from the 2019 general election, in which it ultimately agreed to stand down most candidates and was preparing to become a major force by the time of the next election.
For that, Farage has Tice to thank — and Tice, it seems, has even more questions to address.
I see a lot of people whose jobs are safe enough for the moment, they are utility workers, those who depend on capital intensive industry , largely still public owned (the ones we can’t fire people from). They are the good people who need protection through pay and deferred pay = pensions.
There are also the bad, those in AI and those in hedge funds who know how to profit from these non-people, these non people (AI) need no pay or pension and those who are in control of AI and investment in it are beyond the reach of boring pensions.
What worries me is the middle. The business that can broadly says is software as a service. We have a lot of people in this squeezed middle. A large pension administrator told us last week they employed 1,000 people. What are they doing that cannot be done by AI?
The service industry that relies on software to deliver is vulnerable and that goes not just for jobs but for investments
Alan Livsey explains in the FT that companies that have integral value are worth seeking out. He calls business that is beyond AI as having a halo.
The light blue lines are for sectors and sum up the American market that this is based on. the most resilient are the capital intensive sectors which require our investment whatever. In the middle are a number of sectors that will be hit by AI and at the bottom of the chart are those businesses that need little capital because they will be controlled by AI and need no investment.
Halo focuses on sustainable business models which can survive disruption as much as anything else. Considering this group as “AI-protected companies is the best way to think about this,” says Josh Brown, chief executive at Ritholtz Wealth Management in New York
Brown at Ritholtz is more explicit about the sustainability of this theme.
“I think this is the birth of a new factor in the AI age. Investors will have to think how ‘Halo’ a company is before they pull the trigger on buying a company,”
he argues.
Being a pension man, I will extend Livesy’s argument to pensions. there is a part of the market that will not need pensions in the sense that they were developed since the second world war because retirement will not be necessary. If you are working in a world which has moved on , you will either be servicing the rich and need a pension as you’ll be knackered in your 60’s or you’ll have been served by the AI culture and be rich. I do see society polarising like that.
I see investments that are either capital heavy like utilities where those working in it need pensions and I see – at the other end – people being served by businesses based on software but not employed by them.
Where I see vulnerability is in the middle, those who neither work in the public sector or for organisations that pay pensions because they are dependent on manual labour. Those in the middle are depending on delivering in those areas at the bottom of the chart. Here I see the need for humans to be increasingly limited. What will need to develop is somewhere for humans to be employed and get pensions. We don’t know how this sector will develop though there may be people who can foresee how employment for the vulnerable middle will be reconstitute.
As for those of us, thinking of where to devote pension strategies that replicate the DB plans to a degree, I see those sectors to the top of this chart as needing them.
Those industries that want flexibility because they are not stable but constantly being undermined by AI as the vulnerable middle which will be targeted by those selling the flexibility of DC. At the far end “the bad” are those who profit from the new world of AI and they will not need pensions but can live off self investment and wealth management.
Please don’t laugh at this sales strategy, but it is what I am using to decide upon who best needs protection and who already has protection. If I was in the vulnerable middle I would be looking to secure pension while I can and while I’m needed in work. I think there are huge numbers of us who will not benefit workwise from AI and who need whatever security we can get.
Those at either end don’t need better pensions. Those who are always needed will get DB and those who run the AI show will have wealth. But the middle – the vulnerable middle – need better pensions that give security that they’re not getting from the workplace saving that they’re relying on at present.
My old work friend Alan Chaplin has directed me to an opportunity for CDC which I hadn’t the imagination to see myself. Islamic people , planning for their retirement and a retirement income may need a Shariah pension.
Interesting – seems you and Claude are right corporate-adviser.com/analysis-sha…
CDC gets a mention as being a possible solution – @henrytapper.bsky.social this might be of interest if you’re not already aware.
This leaves he UK’s Muslim population is ageing with 300,000 recorded over 60s in 2021, and another 300,000 expected to reach that age by 2030. They are increasingly reliant on retirement saving (housing is not the growth option it was). Shariah funds exist in most workplace pension schemes but decumulation looks tougher, without a sharia option, Muslims are reluctant to use retirement funds as pensions.
Recent surveys carried out by Islam Channel and Islamic Finance Guru indicate large proportion of Muslims who do not have insurance and pension have cited Shariah compliance issues as the reason.
Muna continues
Of the Muslims that enrol in their workplace pension – approximately 40 per cent cited that the pensions offered by their employers did not offer a Shariah compliant option. This clearly highlights that a large number of Muslims are either avoiding pensions altogether or feeling forced to compromise their beliefs. This situation not only affects individuals’ financial futures but also has broader social and economic implications.
This is one for the Pensions Commission but it may be one for a CDC Proprietor willing to offer a Sharia section of a scheme or maybe a Shariah CDC scheme (though that sounds too exclusive for CDC).
“Annuities are an insurance policy that does not comply with interests and risks. But something that looks and feels like an annuity, I believe exists overseas. There is flexible drawdown, with fixed income that is compliant. There’s a CDC framework now that we can use to design something in decumulation that gives us a lot more flexibility around the underlying investment. DB income is compliant.”
A Shariah section of a CDC scheme could operate an investment policy and comply with other Sharia principles (avoiding annuities and interest based solutions).
Shabna Islam of Hymans Robertson tells Corporate Adviser
..exploring the CDC framework could help design a more flexible, Shariah-compliant alternative to annuities in the UK
My initial reaction as I consider how to build a CDC scheme for 2027 is that simply offering a CDC choice at retirement will be too expensive for the scheme – too lacking in potential take up and yet another choice for Muslim savers that the article accepts are not experienced in taking DC pension choices (who is?)
Robert Reid questions why the issue has been overlooked, stating:
“Given the lengths that were gone to accommodate the Plymouth Brethren with pensions freedoms, one wonders why this hasn’t received more attention before now.”
Meanwhile
Hill emphasises that the challenge is not just on the providers’ side but also within the Muslim community itself, which, he argues, needs more education on financial products to create demand for compliant solutions.
I suspect that a section of a CDC UMES pension scheme would work. There needs to be commitment from employers with Muslim staff and drive from the Muslim community. This is going to take some organising but I’d be happy to discuss how this might work if some of the names quoted in this article can meet ( I can offer meetings with the Pensions Mutual team).
So if you are quoted on Muna Abdi’s article – I’m sure I can find time to be in touch and explore further! henry@agewage.com or henry@pensionsmutual.co.uk
Addressing Bill Sharpe’s “nastiest, hardest problem in finance”
This blog is about the reasons pension master trusts are struggling to pay pensions. The individuals above are Christoph Hirt and Laura Johns whose report for Pi Partnership can be read here.
The first workplace master trust to matter was Nest and it was soon followed by People’s Pension, NOW and then L&G’s. The L&G master trust was a reaction from an insurer to a demand from large employers such as M&S for an occupational pension scheme to let the retailer outsource it’s obligation under auto-enrolment. M&S and a few other large employers employed hundreds of thousands and they and Tesco were among the first employers to “stage” into an L&G master trust.
The promise of L&G became to run outsourced occupational as well as personal pensions for employers who didn’t want to do it themselves. Promises to do this job was quickly followed by others. Standard Life and Aviva, and BlackRock who became Aegon and Zurich who became Scottish Widows, all offered trustee based occupational schemes with continuity for employers and their pension departments to use occupational schemes.
Nest and People’s and NOW were to catch the second , third and fourth waves of smaller employers and sweep up the smaller employers who had no history of pensions.
auto-enrolment traffic (produced by Pension PlayPen at the end of 2012)
It was clear even in 2012 that the strain of AE would be caused by employer size early on and employer numbers towards the end of staging. The new names had no bars to employers and accepted anyone who came their way,
But the insurers were able to pick and chose their customers and underwrite. This meant that they could justify offering ridiculously low prices in return for employer covenant. This wasn’t just a price war for master trusts, (Standard Life offered 10bps to BT staff for a GPP), but as more master trusts sprang up (Smart, Cushon and a host of smaller master trusts), the price war really took off. Grabbing savings took over ,
What happened was a conversion from a pension culture in these schemes to a savings culture. This was accelerated by the announcement in 2014 and implementation after only a year of the pension freedoms. The insurers had underwritten on the basis that all their savers would become customers in retirement using their annuities. BlackRock and Zurich were always going to struggle having no annuity capability but pension freedoms was a challenge and an opportunity which would be faced but not in the AE staging rush and not in the troubles of 2020 when the pandemic bit.
Infact, the insurers had no replacement for annuities and Nest and NOW and People’s were so awash with new customers as the smallest companies staged, that they didn’t have time to get a decumulation in place. The decumulation problem was not solved in the early twenty twenties and this was picked up by a Labour Government with a pension minister with a clear idea of what a workplace pension was.
When Torsten Bell took over from Emma Reynolds he worked with Andrew Tarrant who had worked with Greg McClymont (a shadow pensions minister ten years before). Between them they brought out a Pension Schemes Bill which was presented to parliament last summer. It had at its centre a revitalisation of the workplace as a place where pension are created.
The CDC plans that had reached only Royal Mail, were extended to all employers who prioritise pensions over pension freedom and the workplace DC pensions are fast becoming consolidated into a hardcore which may be reduced to ten or less by the end of this parliament, but a hardcore that will have to deliver a lifetime retirement income as a default. The default will kick in at an age selected by the master trust, will provide real income and real protection either through a retirement income or some kind of flex and fix with the fix being an annuity.
So far only Nest have said they will adopt flex and fix with the annuity kicking in at 85, Esther Hawley of Standard Life told the VFM pod that Standard Life will fix when someone gets to a certain age (this is anecdotal but Esther is reliable)
So far only Willis Towers Watson have said they will offer Retirement CDC as a default for its master trust -Lifesight. Aon are rumoured to be offering CDC and may even offer it as a workplace pension to compete against its own DC master trust. TPT are offering such a workplace version and will continue to run it against its DC master trust, perhaps extending its UMES CDC to be a retirement CDC for its DC members.
CDC is an alternative to a master trust with an exemption from the Scale rules for DC plans. Scale may mean some small DC master trusts convert into CDC plans to avoid losing control of its relationships with employers and members through consolidation.
Tomorrow’s challenge to master trusts is large employers offering workplace pensions through CDC. If these employers leave master trusts for better staff pensions, master trusts will face their biggest challenge since the inception of AE.
Finally, more than 10 years after the introduction of pension freedoms , workplace savings schemes are having to establish a way for people who don’t take decisions to spend the money they have saved.
The original idea (even at Nest and People’s) was a system of annuitisation but that has changed. Right now, the remaining retirement savings plans are looking at ways to become pensions again and it’s proving really complicated. I have listened to over an hour of explanation of Standard’s solution and feel sorry for the job of Esther Hawley in developing a proposition for those retiring. It is a mess for DC, the nastiest hardest problem of finance.
Against the morass that DC decumulation is becoming, CDC may be considered a clean and easy way of improving people’s pension prospects!