It's been a quiet start to the year, but behind the scenes the rocks are beginning to rumble. Consultations are now under way by HMRC on issues flagged by last month's Pre-Budget Report. We reported earlier on the first of these, into whether the lifetime allowance test at benefit crystallisation event 3 and the dependants' scheme pension rules could be made more flexible.

This focuses in particular on the possibility of introducing 'de minimis' limits to reduce the amount of admin work in performing BCE3 LTA tests on small pension increases. Relaxation of the rigid application of the new pensions tax regime rules via such 'de minimis' limits (see eg the earlier announcement on which we reported last September) is surely a sensible way forward.

At the moment this is the only post-PBR consultation document available on the HMRC website. Of the other PBR announcements, alternatively secured pensions (ASPs) and related issues are the subject of a consultation launched today via an email to industry representatives. There are four specific areas on which HMRC is seeking views, as follows:

• the treatment of members untraceable by the time of their 75th birthday;
• anti-avoidance measures;
• the start date of the ASP changes to the transfer lump sum death benefit rules and the guarantee facility; and
• the interaction of the inheritance tax and ASP charges.

Meetings of interested parties are to be held this month. For a copy of the consultation document, please contact Aries.

The PBR announcement on ASP was not unexpected, but the withdrawal of pension term assurance (PTA) was a real bombshell. HMRC is in discussions about the practical consequences of this with a small number of representatives of industry bodies, including the ABI, SPC, ILAG and AIFA. A meeting is to be held shortly. No condoc yet exists of which we are aware (but watch this space).