In S Lefort v HMRC [2024] UKFTT 926 (TC) (17 October) the FTT upheld HMRC’s decision to revoke the taxpayer’s certificate of fixed protection under the legislation reducing the pension schemes lifetime allowance in 2014.
The taxpayer was an airline pilot employed by Virgin Airlines. He had a self-invested pension plan (SIPP) into which he and Virgin made contributions. He left the company in February 2014 making a final contribution to the plan and obtained a Fixed Protection 2014 certificate. Virgin however did not pay its final contribution until May 2014 after the cut-off date under the fixed protection regulations. As a result HMRC exercised their power to revoke the certificate and the taxpayer appealed against that decision.
The taxpayer argued that Virgin made the contribution later than it should have done (the late contribution point) and/or that...
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In S Lefort v HMRC [2024] UKFTT 926 (TC) (17 October) the FTT upheld HMRC’s decision to revoke the taxpayer’s certificate of fixed protection under the legislation reducing the pension schemes lifetime allowance in 2014.
The taxpayer was an airline pilot employed by Virgin Airlines. He had a self-invested pension plan (SIPP) into which he and Virgin made contributions. He left the company in February 2014 making a final contribution to the plan and obtained a Fixed Protection 2014 certificate. Virgin however did not pay its final contribution until May 2014 after the cut-off date under the fixed protection regulations. As a result HMRC exercised their power to revoke the certificate and the taxpayer appealed against that decision.
The taxpayer argued that Virgin made the contribution later than it should have done (the late contribution point) and/or that...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
