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LTA Excess Charge Abolition

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  • zagfles
    zagfles Posts: 21,486 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Chutzpah Haggler
    From a quick skim...
    Looks like they've relented on the original proposal which would have meant you couldn't inherit a tax free pension, just a lump sum (see the bit about BCE5C/D).
    It mentions transitional arrangement when moving from LTA to lump sum allowances with no real detail, but judging by this statement "Where an individual has previously used 100% of their LTA, they will have exhausted their allowances and the transitional calculation will not apply" it would seem that if someone eg takes a DB this year with no PCLS and uses up their LTA, they won't be able to take PCLS from a DC to use up any remaining PCLS allowance. Yet preumably if they took the DB next tax year with no PCLS, that wouldn't use up PCLS allowance and so wouldn't reduce the allowance.
    Although it goes on to say "Members with complete and accurate records of the previous tax-free amounts they have received will have opportunity to provide these records to their scheme for an alternative transitional calculation" but unclear if that would apply when LTA used up.
    All a bit vague at the moment.
  • FIREDreamer
    FIREDreamer Posts: 1,008 Forumite
    500 Posts Second Anniversary Name Dropper Photogenic
    The Finance Act 2024 document is very difficult to understand especially regarding what PCLS may be available post 6 April 2024.

    If someone has used all LTA before 6/4/2024 but when putting a DB pension into payment did not take any PCLS at the time, they theoretically have a lump sum allowance available. Is a transitional certificate of any use here or does the fact that no LTA remains mean that this option is unavailable.

    If so, there is a potential cliff edge - person A has taken a DB pension with no PCLS and used 99.9% LTA and has £258k future PCLS available but person B took a slightly bigger DB pension at the same time with no PCLS at 100% LTA has no future PCLS available. This couldn’t be the intention surely?
  • zagfles
    zagfles Posts: 21,486 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Chutzpah Haggler
    edited 22 February 2024 at 3:55PM
    As I understand it there won't be a cliff edge and those who've used 100% LTA can still apply for a "Transitional tax-free amount certificate".
    See Q 7 here
    It does look to be an irreversable decision though, if it turns out you'd be better off using the standard calculation you can't go back to that! For some people eg who've crystallised when the LTA was much higher they could be worse off. See example in the links below
    Also see





  • FIREDreamer
    FIREDreamer Posts: 1,008 Forumite
    500 Posts Second Anniversary Name Dropper Photogenic
    edited 22 February 2024 at 4:57PM
    zagfles said:
    As I understand it there won't be a cliff edge and those who've used 100% LTA can still apply for a "Transitional tax-free amount certificate".
    See Q 7 here
    It does look to be an irreversable decision though, if it turns out you'd be better off using the standard calculation you can't go back to that! For some people eg who've crystallised when the LTA was much higher they could be worse off. See example in the links below
    Also see


    Hargreaves Lansdown have said the following …

    “Please find attached a table of the LTA you have used. Please note that you are fully in excess of your Lifetime Allowance and therefore do not have any tax free cash entitlement remaining. If you did not take tax free cash at the time with EXISTING DB SCHEME, this is something that you would need to discuss with them, however please be aware that it is unlikely that this will still be available to you now.”

    From what you say, they have got this wrong?

    Tagging @dunstonh as he might have clients in a similar position maybe?
  • zagfles
    zagfles Posts: 21,486 Forumite
    Part of the Furniture 10,000 Posts Name Dropper Chutzpah Haggler
    edited 22 February 2024 at 6:39PM
    FIREDreamer said:
    zagfles said:
    As I understand it there won't be a cliff edge and those who've used 100% LTA can still apply for a "Transitional tax-free amount certificate".
    See Q 7 here
    It does look to be an irreversable decision though, if it turns out you'd be better off using the standard calculation you can't go back to that! For some people eg who've crystallised when the LTA was much higher they could be worse off. See example in the links below
    Also see


    Hargreaves Lansdown have said the following …

    “Please find attached a table of the LTA you have used. Please note that you are fully in excess of your Lifetime Allowance and therefore do not have any tax free cash entitlement remaining. If you did not take tax free cash at the time with EXISTING DB SCHEME, this is something that you would need to discuss with them, however please be aware that it is unlikely that this will still be available to you now.”

    From what you say, they have got this wrong?

    Tagging @dunstonh as he might have clients in a similar position maybe?
    This is all very new, and they are right that no tax free cash would be available NOW, as we're still under the old rules albeit with no LTA charge. Also the Finance bill 2023/24 hasn't got royal assent yet, it's due today by the looks of it. I don't think HL or anyone will be telling you what you can do based on rule changes which haven't yet become law.
    But assuming Charlie does rubber stamp it, from my understanding reading the above links is, after April if you've not taken £268,275 in PCLS's then you'd be able to apply for a "transitional tax-free amount certificate" and take the remainder from a DC pension, but still subject to max 25%. So for instance if you've taken £200k in PCLS, and your uncrystallised DC pot was £100k you'd be able to take £25k tax free from it. If it was £300k you'd be able to take £68,275 from it (ie the remainder of the lump sum allowance)
  • Notepad_Phil
    Notepad_Phil Posts: 1,561 Forumite
    Fifth Anniversary 1,000 Posts Name Dropper
    FIREDreamer said:
    zagfles said:
    As I understand it there won't be a cliff edge and those who've used 100% LTA can still apply for a "Transitional tax-free amount certificate".
    See Q 7 here
    It does look to be an irreversable decision though, if it turns out you'd be better off using the standard calculation you can't go back to that! For some people eg who've crystallised when the LTA was much higher they could be worse off. See example in the links below
    Also see


    Hargreaves Lansdown have said the following …

    “Please find attached a table of the LTA you have used. Please note that you are fully in excess of your Lifetime Allowance and therefore do not have any tax free cash entitlement remaining. If you did not take tax free cash at the time with EXISTING DB SCHEME, this is something that you would need to discuss with them, however please be aware that it is unlikely that this will still be available to you now.”

    From what you say, they have got this wrong?

    Tagging @dunstonh as he might have clients in a similar position maybe?
    Nothing has actually been changed yet, so I assume HL are quoting based on current legislation, not on what the proposed legislation may bring in. I would think that you'll need to wait until the new laws are definitely known before asking a provider on such details.
  • FIREDreamer
    FIREDreamer Posts: 1,008 Forumite
    500 Posts Second Anniversary Name Dropper Photogenic
    edited 22 February 2024 at 6:45PM
    zagfles said:
    FIREDreamer said:
    zagfles said:
    As I understand it there won't be a cliff edge and those who've used 100% LTA can still apply for a "Transitional tax-free amount certificate".
    See Q 7 here
    It does look to be an irreversable decision though, if it turns out you'd be better off using the standard calculation you can't go back to that! For some people eg who've crystallised when the LTA was much higher they could be worse off. See example in the links below
    Also see


    Hargreaves Lansdown have said the following …

    “Please find attached a table of the LTA you have used. Please note that you are fully in excess of your Lifetime Allowance and therefore do not have any tax free cash entitlement remaining. If you did not take tax free cash at the time with EXISTING DB SCHEME, this is something that you would need to discuss with them, however please be aware that it is unlikely that this will still be available to you now.”

    From what you say, they have got this wrong?

    Tagging @dunstonh as he might have clients in a similar position maybe?
    This is all very new, and they are right that no tax free cash would be available NOW, as we're still under the old rules albeit with no LTA charge. Also the Finance bill 2023/24 hasn't got royal assent yet, it's due today by the looks of it. I don't think HL or anyone will be telling you what you can do based on rule changes which haven't yet become law.
    But assuming Charlie does rubber stamp it, from my understanding reading the above links is, after April if you've not taken £268,275 in PCLS's then you'd be able to apply for a "transitional tax-free amount certificate" and take the remainder from a DC pension, but still subject to max 25%. So for instance if you've taken £200k in PCLS, and your uncrystallised DC pot was £100k you'd be able to take £25k tax free from it. If it was £300k you'd be able to take £68,275 from it (ie the remainder of the lump sum allowance)

    Thanks


    Notepad_Phil said:
    FIREDreamer said:
    zagfles said:
    As I understand it there won't be a cliff edge and those who've used 100% LTA can still apply for a "Transitional tax-free amount certificate".
    See Q 7 here
    It does look to be an irreversable decision though, if it turns out you'd be better off using the standard calculation you can't go back to that! For some people eg who've crystallised when the LTA was much higher they could be worse off. See example in the links below
    Also see


    Hargreaves Lansdown have said the following …

    “Please find attached a table of the LTA you have used. Please note that you are fully in excess of your Lifetime Allowance and therefore do not have any tax free cash entitlement remaining. If you did not take tax free cash at the time with EXISTING DB SCHEME, this is something that you would need to discuss with them, however please be aware that it is unlikely that this will still be available to you now.”

    From what you say, they have got this wrong?

    Tagging @dunstonh as he might have clients in a similar position maybe?
    Nothing has actually been changed yet, so I assume HL are quoting based on current legislation, not on what the proposed legislation may bring in. I would think that you'll need to wait until the new laws are definitely known before asking a provider on such details.

    Thanks as well. Retiring in June and aiming to get my ducks in a row ready!

    I think I have £22k or so of potential PCLS available compared to the £268k available. So potential tax saving of £4.4k or so - worth having but not a massive deal. But saving on the LTA charge anyway so the PCLS would only be icing on the cake and it’s a first world problem anyway.

    Makes doing the £3,600 round robin post retirement to age. 75 worthwhile - pointless if no PCLS available though but small pots also an option.
  • RogerPensionGuy
    RogerPensionGuy Posts: 772 Forumite
    500 Posts Third Anniversary Photogenic Name Dropper
    edited 23 February 2024 at 1:52AM
    The below messages have been going around today and may be helpful to some.
    ☆☆☆
    .
    The lifetime allowance is changing – everything you need to know
    From 6 April 2024, the lifetime allowance (LTA) is changing. Here’s everything you need to know about the new pension rules, including the three new allowances

    Written by
    Adam Kemp
    Published Feb 21, 2024




    Important information - This article isn’t personal advice. If you’re not sure whether an investment is right for you please seek advice. If you choose to invest the value of your investment will rise and fall, so you could get back less than you put in.

    From 6 April 2024, the lifetime allowance rules will be abolished and replaced with three new allowances – here’s what you need to know.
    This article isn’t personal advice. The information is based on our understanding of HMRC announcements as of 14 February and, like all tax rules, can change. Any benefits depend on your circumstances. If you’d like help from our expert financial advisers, ask for financial advice.
    Out with the old – how is the lifetime allowance changing?
    There used to be a limit on the total value of pension benefits you could build up throughout your lifetime and generally receive up to 25% tax free. This limit was known as the lifetime allowance (LTA) and was set at £1,073,100 for most people.
    Normally, if the value of your pension benefits grew beyond the LTA, any excess would be subject to a tax charge. However, from 6 April 2024 the LTA rules will be abolished and replaced by three new allowances.
    In with the new – the new allowances replacing the LTA
    The three new allowances are the lump sum allowance (LSA), lump sum and death benefit allowance (LSDBA), and the overseas transfer allowance (OTA).
    The new lump sum allowance
    The lump sum allowance limits the amount which can be taken out of pensions tax free to £268,275 for most people.
    However, there could be scenarios where some individuals might be able to receive additional tax-free amounts, when these new changes come into effect, which they wouldn’t have been entitled to under the current rules. Nevertheless, this is nuanced and will depend on a number of factors.
    What if you previously accessed final salary benefits?
    This is potentially more relevant to those with previous defined benefit pensions where they might have taken a higher starting pension income, for example, in exchange for a lower, or even no, tax-free cash payment. Where no tax-free cash was taken before, it’s lost under current rules, and could still be lost under the new rules.
    What if you registered for LTA protection?
    From next tax year, the maximum amount you can take tax free is usually limited to the LSA of £268,275. However, some individuals could have a different limit if they applied for protection in relation to previous changes to the lifetime allowance.
    New transitional tax-free amount certificate (TTFA)
    The new rules could let some individuals (or, if deceased, their personal representatives) to apply for a TTFA certificate by providing evidence of how much has been withdrawn tax free in the past.
    This could potentially allow them (or their beneficiaries) to take more tax free than they would’ve been able to under the current rules, or under HMRC’s standard transitional calculation.
    Who could consider applying for a TTFA?
The following also apply to personal representatives applying on behalf of deceased individuals.
    1. Anyone who didn’t commute their defined benefits pensions or possibly those who might have taken a guaranteed annuity rate only from their defined contribution pension. 
    2. Those who might have accessed pension benefits when the LTA was below £1,073,100 across the four tax years from tax year 2016-2017 to tax year 2019-2020. In these tax years, the amount which could’ve been withdrawn tax free could’ve been based on 25% of a lower LTA threshold.
    3. Anyone who used lifetime allowance as a result of transferring to a qualifying recognised overseas pension scheme (QROPS). 
    4. Those over the age of 75 where pension benefits remain untaken. Funds will have been tested against the LTA at age 75 which could’ve used some or all of the LTA, with the standard calculation applying 25% of the LTA . 
    5. Those who’ve used all of their lifetime allowance
    6. Those who have pensions in payment from before 6 April 2006 that have used their lifetime allowance.
    For those who’ve never previously used any lifetime allowance and don’t have protection against the LTA, then this arguably becomes a simpler exercise. The lump sum allowance (LSA) limits the amount which can be taken tax free to £268,275.
    You can only apply for a TTFA certificate before the first time the individual uses any of their LSA or LSDBA after 5 April 2024.
    How the standard transitional calculation works
    If you’ve used any of your lifetime allowance before 6 April 2024, how much of your LSA and LSDBA you have left will usually be calculated using a ‘standard transitional calculation’ set out by HMRC.
    For most people this will be done by multiplying the amount of lifetime allowance they’ve used by 25% and deducting the result from both allowances.
    For example, if you’ve used 50% of your lifetime allowance the calculation would be:
    * 50% x £1,073,100 x 25% = £134,137.50
    * Remaining lump sum allowance = £268,257 - £134,137.50 = £134,137.50
    * Remaining lump sum and death benefit allowance = £1,073,100 - £134,137.50 = £938,962.50.
    If you’ve used all of your lifetime allowance, you’ll usually be deemed to have no available LSA or LSDBA.
    The lump sum and death benefit allowance
    For most people the lump sum and death benefit allowance will be £1,073,100.
    Like the LSA, certain types of payment will use up your LSDBA.
    Those payments include:
    * Pension commencement lump sums (PCLS) 
    * The tax-free element of an Uncrystallised Funds Pension Lump Sum (UFPLS) 
    * The tax-free element of serious ill health lump sums 
    * Non-taxable lump sum death benefits, excluding charity lump sum death benefits, trivial commutation lump sum death benefits, lump sum death benefits paid from funds crystallised before 6 April 2024, and lump sum death benefits paid from beneficiary drawdown funds. 
    The above lump sums are all examples of what are called ‘Relevant Benefit Crystallisation Events’ (RBCEs).
    The overseas transfer allowance
    This new allowance covers transfers to qualifying recognised overseas pension schemes (QROPS). It’s also set at the amount of the old lifetime allowance – £1,073,100, for most people.
    How does the overseas transfer allowance work in practice?
Let’s say you haven’t yet taken any pension benefits and decide you’d like to move £100,000 of your pension into drawdown. Typically, up to 25% of the amount being moved into drawdown can be paid as a tax-free lump sum (PCLS).
    Under the new rules – it would only be the PCLS (tax-free cash) amount of £25,000 that would use up your LSA and LSDBA.
    So, after taking that PCLS, you’d have £243,275 of your LSA and £1,048,100 of your LSDBA left.
    If you exceed the LSA or LSDBA, any excess will be taxed at either yours or your beneficiaries’ marginal income tax rate. Transfers to QROPS that exceed the overseas transfer allowance will normally be subject to the Overseas Transfer Charge (OTC) of 25%.
    Understanding the impact on beneficiaries is also crucial. If you pass away before 75, lump sums within the allowances are generally tax free. After 75, your beneficiaries will need to pay income tax at their marginal rate on any benefits they receive.
    Get help from an expert financial adviser
    This is a very complex area, but it’s important to know all your options and make the most of them – this is where financial advice can help.
    Our financial advisers can assess the rules against your circumstances and provide personalised recommendations.
    The first step is to book a call with our advisory helpdesk. While our helpdesk won’t give you advice themselves, they’ll help you decide if taking advice is right for you, and discuss the costs involved.
    ☆☆☆
    ☆☆☆

    This link below may also be of interest, it also contains some nice subjects that can be viewed also. 
    ☆☆☆
    ☆☆☆
    https://www.ajbell.co.uk/articles/investmentarticles/269217/government-confirms-pension-tax-rules-following-lifetime
  • FIREDreamer
    FIREDreamer Posts: 1,008 Forumite
    500 Posts Second Anniversary Name Dropper Photogenic
    RogerPensionGuy said:
    The below messages have been going around today and may be helpful to some.
    ☆☆☆
    .
    The lifetime allowance is changing – everything you need to know
    From 6 April 2024, the lifetime allowance (LTA) is changing. Here’s everything you need to know about the new pension rules, including the three new allowances

    Written by
    Adam Kemp
    Published Feb 21, 2024




    Important information - This article isn’t personal advice. If you’re not sure whether an investment is right for you please seek advice. If you choose to invest the value of your investment will rise and fall, so you could get back less than you put in.

    From 6 April 2024, the lifetime allowance rules will be abolished and replaced with three new allowances – here’s what you need to know.
    This article isn’t personal advice. The information is based on our understanding of HMRC announcements as of 14 February and, like all tax rules, can change. Any benefits depend on your circumstances. If you’d like help from our expert financial advisers, ask for financial advice.
    Out with the old – how is the lifetime allowance changing?
    There used to be a limit on the total value of pension benefits you could build up throughout your lifetime and generally receive up to 25% tax free. This limit was known as the lifetime allowance (LTA) and was set at £1,073,100 for most people.
    Normally, if the value of your pension benefits grew beyond the LTA, any excess would be subject to a tax charge. However, from 6 April 2024 the LTA rules will be abolished and replaced by three new allowances.
    In with the new – the new allowances replacing the LTA
    The three new allowances are the lump sum allowance (LSA), lump sum and death benefit allowance (LSDBA), and the overseas transfer allowance (OTA).
    The new lump sum allowance
    The lump sum allowance limits the amount which can be taken out of pensions tax free to £268,275 for most people.
    However, there could be scenarios where some individuals might be able to receive additional tax-free amounts, when these new changes come into effect, which they wouldn’t have been entitled to under the current rules. Nevertheless, this is nuanced and will depend on a number of factors.
    What if you previously accessed final salary benefits?
    This is potentially more relevant to those with previous defined benefit pensions where they might have taken a higher starting pension income, for example, in exchange for a lower, or even no, tax-free cash payment. Where no tax-free cash was taken before, it’s lost under current rules, and could still be lost under the new rules.
    What if you registered for LTA protection?
    From next tax year, the maximum amount you can take tax free is usually limited to the LSA of £268,275. However, some individuals could have a different limit if they applied for protection in relation to previous changes to the lifetime allowance.
    New transitional tax-free amount certificate (TTFA)
    The new rules could let some individuals (or, if deceased, their personal representatives) to apply for a TTFA certificate by providing evidence of how much has been withdrawn tax free in the past.
    This could potentially allow them (or their beneficiaries) to take more tax free than they would’ve been able to under the current rules, or under HMRC’s standard transitional calculation.
    Who could consider applying for a TTFA?
The following also apply to personal representatives applying on behalf of deceased individuals.
    1. Anyone who didn’t commute their defined benefits pensions or possibly those who might have taken a guaranteed annuity rate only from their defined contribution pension. 
    2. Those who might have accessed pension benefits when the LTA was below £1,073,100 across the four tax years from tax year 2016-2017 to tax year 2019-2020. In these tax years, the amount which could’ve been withdrawn tax free could’ve been based on 25% of a lower LTA threshold.
    3. Anyone who used lifetime allowance as a result of transferring to a qualifying recognised overseas pension scheme (QROPS). 
    4. Those over the age of 75 where pension benefits remain untaken. Funds will have been tested against the LTA at age 75 which could’ve used some or all of the LTA, with the standard calculation applying 25% of the LTA . 
    5. Those who’ve used all of their lifetime allowance
    6. Those who have pensions in payment from before 6 April 2006 that have used their lifetime allowance.
    For those who’ve never previously used any lifetime allowance and don’t have protection against the LTA, then this arguably becomes a simpler exercise. The lump sum allowance (LSA) limits the amount which can be taken tax free to £268,275.
    You can only apply for a TTFA certificate before the first time the individual uses any of their LSA or LSDBA after 5 April 2024.
    How the standard transitional calculation works
    If you’ve used any of your lifetime allowance before 6 April 2024, how much of your LSA and LSDBA you have left will usually be calculated using a ‘standard transitional calculation’ set out by HMRC.
    For most people this will be done by multiplying the amount of lifetime allowance they’ve used by 25% and deducting the result from both allowances.
    For example, if you’ve used 50% of your lifetime allowance the calculation would be:
    * 50% x £1,073,100 x 25% = £134,137.50
    * Remaining lump sum allowance = £268,257 - £134,137.50 = £134,137.50
    * Remaining lump sum and death benefit allowance = £1,073,100 - £134,137.50 = £938,962.50.
    If you’ve used all of your lifetime allowance, you’ll usually be deemed to have no available LSA or LSDBA.
    The lump sum and death benefit allowance
    For most people the lump sum and death benefit allowance will be £1,073,100.
    Like the LSA, certain types of payment will use up your LSDBA.
    Those payments include:
    * Pension commencement lump sums (PCLS) 
    * The tax-free element of an Uncrystallised Funds Pension Lump Sum (UFPLS) 
    * The tax-free element of serious ill health lump sums 
    * Non-taxable lump sum death benefits, excluding charity lump sum death benefits, trivial commutation lump sum death benefits, lump sum death benefits paid from funds crystallised before 6 April 2024, and lump sum death benefits paid from beneficiary drawdown funds. 
    The above lump sums are all examples of what are called ‘Relevant Benefit Crystallisation Events’ (RBCEs).
    The overseas transfer allowance
    This new allowance covers transfers to qualifying recognised overseas pension schemes (QROPS). It’s also set at the amount of the old lifetime allowance – £1,073,100, for most people.
    How does the overseas transfer allowance work in practice?
Let’s say you haven’t yet taken any pension benefits and decide you’d like to move £100,000 of your pension into drawdown. Typically, up to 25% of the amount being moved into drawdown can be paid as a tax-free lump sum (PCLS).
    Under the new rules – it would only be the PCLS (tax-free cash) amount of £25,000 that would use up your LSA and LSDBA.
    So, after taking that PCLS, you’d have £243,275 of your LSA and £1,048,100 of your LSDBA left.
    If you exceed the LSA or LSDBA, any excess will be taxed at either yours or your beneficiaries’ marginal income tax rate. Transfers to QROPS that exceed the overseas transfer allowance will normally be subject to the Overseas Transfer Charge (OTC) of 25%.
    Understanding the impact on beneficiaries is also crucial. If you pass away before 75, lump sums within the allowances are generally tax free. After 75, your beneficiaries will need to pay income tax at their marginal rate on any benefits they receive.
    Get help from an expert financial adviser
    This is a very complex area, but it’s important to know all your options and make the most of them – this is where financial advice can help.
    Our financial advisers can assess the rules against your circumstances and provide personalised recommendations.
    The first step is to book a call with our advisory helpdesk. While our helpdesk won’t give you advice themselves, they’ll help you decide if taking advice is right for you, and discuss the costs involved.
    ☆☆☆
    ☆☆☆

    This link below may also be of interest, it also contains some nice subjects that can be viewed also. 
    ☆☆☆
    ☆☆☆
    https://www.ajbell.co.uk/articles/investmentarticles/269217/government-confirms-pension-tax-rules-following-lifetime
    More pension simplification 😂😂😂😂😂
  • Pat38493
    Pat38493 Posts: 3,336 Forumite
    Part of the Furniture 1,000 Posts Name Dropper Combo Breaker
    Do I understand from this that if you took a DB pension prior to these changes with the full amount of PCLS, you won't be eligable for any kind of certificate?

    If you did this, wouldn't your future TFC be limited not only by the PCLS that you took, but by the 20xDB amount multiplier, so you will be worse off in the end?
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