Guidance on pension tax relief limits: Your Lifetime Allowance

What is the Lifetime Allowance?

This is an overall value of pension benefits you can build up across all types of registered pension schemes without HMRC applying additional tax charges to your pension benefits.

What does this guidance cover?

The purpose of this guidance is to support and complement the information available on the Finance Division’s Pensions website, USS and HMRC websites. This webpage also sets out some on how the University’s Pensions Office can assist you.

It should be noted that you are responsible for keeping track of your total pension benefits in relation to the Lifetime Allowance (“LTA”), as this is a personal taxation matter.  It is particularly important if you have pension benefits (approved by HMRC) from other employments or private pension arrangements because these also count towards the LTA.  It is the responsibility of an employee to manage their own allowances and tax position.

The Pensions Office will support you by providing you with information on request to enable you to review your personal position.  It is better to be aware of the potential for a tax charge to be incurred and to mitigate this where possible before this point is reached.  In the first instance, you should familiarise yourself with the information available on the dedicated areas of the above websites, where there are various related resources to assist you.  For more in-depth information about the LTA, please refer to the HMRC website.

Who is most likely to be affected?

The LTA will not affect the vast majority of people.  To exceed the £1.00 million LTA you would need to have 40 years’ service in a pension scheme such as USS and with a pensionable salary of around £86,000 a year.

A member of a defined benefit scheme,  a pension of around £56,000 p.a. and tax free cash lump sum of £168,000 would give an LTA value of £1.3 million (20 x £56,000 +£168,000 = £1,288,000).

If you have other pension savings these would also add to the value of the LTA.

What should I do?

Familiarise yourself with the information on USS and HMRC websites and below, take independent financial advice if appropriate, check the value of your pension benefits and consider if applying for tax protection is an option.

What can you do if you are likely to exceed the lower LTA?

The LTA is not a limit as such.  Your pension benefits can be over the LTA, but generally any benefits paid by a pension scheme above the LTA will subject to a tax charge (the LTA charge).

HMRC has provided transitional protection – Fixed Protection 2016 (“FP16”) and Indvidual Protection 2016 (“IP16”). 

What is Fixed Protection 2016?

Fixed Protection 2016 entitles individuals to an LTA of £1.25 million.  Any new pension savings made by or on behalf of the individual on or after 6 April 2016 are likely to lead to the loss of FP16. 

What is Individual Protection 2016?

Under Individual Protection 16 (‘IP16') individuals may elect for a personalised LTA based on the value of their pension savings at 5 April 2016 (up to £1.25 million). It will allow individuals to continue pension saving after 5 April 2016 whilst protecting tax relieved pension savings that have accrued up to that date, subject to an overall maximum of £1.25 million.  Individuals will have three years from 6 April 2016 to apply for IP16. Details are available from HMRC.

Individuals can hold both FP16 and IP16, subject to meeting the eligibility conditions.

IP16 will be available to individuals with pension savings of more than £1.00 million on 5 April 2016, providing they do not have existing primary or enhanced protection from the LTA charge.

What options are offered by USS to mitigate any tax?

There are USS tax relief options: These were introduced to assist members who may have or are likely to have a Lifetime Allowance or Annual Allowance charge. 

If, after weighing up the choices and USS options available, and after taking obtaining financial advice, it is concluded you need to choose one of the three options available from USS, you should proceed as follows:

Making an election for one of the USS tax relief options: An election form (separate form for each of the tax relief limits options) can be downloaded directly from the USS website, noting that USS requires 28 days notice in writing before the date of the election. All completed Election Forms should be sent to the Pensions Office, not to USS directly.

USS Money Purchase (Prudential) AVCs (MPAVCs),USS Investment Builder AVCs and USS match:  If you currently pay these, you may wish to consider reducing or ceasing these payments if your benefits are or may become above the LTA.  If you decide to reduce or cease your MPAVCs or discuss the level of contributions, you will need to contact Prudential directly - call the customer call centre on 0845 600 0343. To change your USS  choices, log onto myUSS.

If, after considering the actions and options available to you, including those above, and it is identified you are likely to exceed the LTA limit, there are other options below to consider.

Will USS let me know if I am over the LTA?

USS will not routinely tell you if your benefits within USS exceed the LTA.  You must keep track of your benefits.  At various times USS have to check whether a member's pension savings have exceeded the lifetime allowance rate - this happens when what is known as a 'benefit crystallisation event' (BCE) occurs.  For example, when USS start paying a pension to a member it must tell the member what percentage of the lifetime allowance they've used up and provide this information at least once every tax year.

What is the Annual Allowance (AA)

The Annual Allowance limits the contributions and/or pension benefits that you can build up each year without additional tax charges. If your pension benefits build up by more than your available Annual Allowance (including any carried forward from previous years) the excess is taxed at your marginal rate.

What are the limits?

  • The Lifetime Allowance (LTA) is £1.00m with effect from 6 April 2016 (down from £1.25m on 6 April 2014).

The Lifetime Allowance (LTA) will then be increased by CPI from 6 April 2018.

The Government  restricted pension tax relief for high earners by introducing a tapered reduction in the amount of AA for individuals with income (including the value of any pension contributions) of over £150,000, and who have an income (excluding pension contributions) in excess of £110,000. This change came into effect on 6 April 2016. For more information please visit the HMRC site.

How can the Pensions office help?

The University Pensions Office can explain the background to pension taxation and explain information provided by USS. We cannot give you advice or help with tax planning. For this you may want to consult your accountant, or an independent financial advisor.