Registered Pension Schemes Manual: HMRC issues major update
by Ian Neale 01/09/2006      Back to previous page

The second post-A Day update to the Registered Pension Schemes Manual (RPSM), published on 30 August, includes changes to every chapter and a substantial number of new pages (Member, Scheme Administrator and Employer as well as the Technical pages). This is a full version including Chapter 3 on protection, which had been missing for several months. All the Technical chapters are also available - including for the first time Chapter 7 on Investments - as updated printable PDF files.

This version includes the amendments required as a result of Finance Act 2006 and the regulations that were laid in July, and indeed (we hope) all the rest of the relevant legislation laid since February 2006 which up to now has not been covered. HMRC has also made a number of improvements to the original pages, based on suggestions and comments from Aries and others in the industry. All the pages that were previously "under development" have been finalised.

The full list of amendments covers new pages, a few deleted sections and many updated pages. A pdf version of this list will be available shortly (at the time of writing, the published link is to the last (May 2006) update). The Aries team is already working on these changes to update the fully-searchable copy of the RPSM included in the Aries Pensions System.

HMRC's view now, stated in Pensions Tax Simplification Newsletter No 18, is that with the publication of this version of the RPSM, the vast majority of queries in relation to the new pensions tax rules and the operation of registered pension schemes can now be answered on a 'self-serve' basis. (For queries not covered, there is a new email help facility Pensionschemes@hmrc.gov.uk). We are also assured that the RPSM will be kept under review and periodic updates will be made where changes are required.

Other matters covered in this issue of HMRC’s regular monthly Newsletter:

Transfers of unvested funds: any lump sum paid prior to the transfer will not be a PCLS, and therefore will be an unauthorised payment. This query arose in the context of a transfer to another scheme run by another provider, with the intention of going into drawdown (USP).

Definition of Halls of Residence: these are excepted from the taxable (residential) property rules under FA 2006, and thus are an attractive investment for investment regulated pension schemes. HMRC sets out the characteristics, which make it clear that to be a hall of residence it is not sufficient that the accommodation is or may only be let to students.

Taxation of trivial commutation payments: on request, HMRC may allow use of the recipient's tax code from the previous employment or another code, instead of the Week 1 or Month 1 basis prescribed elsewhere.

Changes to the Event Report and Scheme Registration Forms: these won't come into force until April 2007, but final drafts of the new versions, based on the FA 2006 changes, are available now.

Accounting for Tax returns: chaos alert: the AFT requires the amount to be rounded down to whole pounds, although systems will often generate payments to the nearest penny. If the payment does not precisely match the amount on the AFT, it is vital to quote the correct charge reference. Furthermore, HMRC warns, "if you become aware of an error in an AFT you should make an amended AFT to APSS for the quarter concerned. Do not try to correct a submitted AFT by way of an adjustment in a return for a later quarter".

Continuous service: In general, under the pre-A Day regime, benefits could only be provided by an employer in respect of service with that employer. However, service periods with different employers could be aggregated in special circumstances where the service could be regarded as continuous, eg in takeover/ merger situations, or a move between two employers within a Centralised Scheme. In such cases, where the member was a controlling director HMRC's prior agreement that the service can be treated as continuous was required, via form PS155 (PSO Update No 142) [PDF]. However, if the change of employer, transfer of funds, or payment of retirement benefits occurs after A Day, form PS155 is no longer relevant because continuous service is no longer an issue.