From tax year 2016/17, a reduced annual allowance may apply to all pension savings by or on behalf of a member, depending on the level of taxable income within the tax year.
The tapered annual allowance was introduced from 6 April 2016.
For the taper to apply, the limits on threshold income and adjusted income must both be exceeded.
For every £2 of adjusted income over £150,000, an individual’s annual allowance is reduced by £1.
Why the tapered annual allowance was introduced
From tax year 2016/17, a reduced annual allowance may apply to all pension savings by or on behalf of a member, depending on their level of taxable income within the tax year.
On 6 April 2016 the government introduced the Tapered Annual Allowance for individuals with “threshold income” of over £110,000 AND "adjusted income" of over £150,000.
Where an individual has a "Threshold income" of £110,000 or less they cannot be subject to the tapered annual allowance and there is no requirement to calculate adjusted income. If threshold income exceeds £110,000 you must calculate adjusted income to work out the amount of any tapered annual allowance.
The threshold income measure helps to provide certainty for individuals with lower salaries who may have one off spikes in their employer pension contributions. If the individual’s net (taxable) income is no more than £110,000 they will not normally be subject to the tapered annual allowance. However, anti-avoidance rules will apply so that any salary sacrifice for pension savings set up on or after 9 July 2015 will be included in the threshold income calculation.
"Threshold Income" is broadly defined as ‘the individual’s net income for the year, this will include all taxable income such as, dividend income, pensions income, interest on savings, rental income etc, less the amount of any taxable lump sum death benefits paid to the individual during the tax year that can be deducted from the threshold income.’
In more detail "threshold income" is:
Taxable income for the tax year less
Any taxable lump sum pension death benefits accruing in the tax year (ITEPA 2003 section 636A-4ZA) plus
Employment income given up for pension contributions (i.e. salary sacrifice) under an arrangement made on or after 9 July 2015 less
The gross amount of any relief at source (to ensure that when calculating threshold income, there is parity between any contributions made under net pay, which are deducted arriving at taxable income, and relief at source).
The ‘adjusted income’ definition adds in all employer pension contributions, to prevent individuals from avoiding the restriction by exchanging salary for employer contributions. For those in defined benefit or cash balance arrangements, the value of the employer contribution will be calculated using the annual allowance methodology. That is the employer contribution will be the pension input amount for the arrangement, less the amount of any contributions made by the individual during the tax year.
The process for calculating adjusted income
1) Identify the amounts of income on which the taxpayer is charged to income tax for the tax year. The sum of those amounts is "total income". Each of those amounts is a "component" of total income (components of this income will include all taxable income such as dividend income, pensions income, interest on savings, rental income etc.). This is Step 1 in the calculation section of the Income Tax Act 2007.
2) Deduct from the components the amount of any relief under a provision listed in relation to the taxpayer in section 24 to which the taxpayer is entitled for the tax year. See section 25 for further provision about the deduction of those reliefs. The sum of the amounts of the components left after this step is "net income". This is Step 2 in the calculation section of the Income Tax Act 2007. Also for more information on reliefs deductible, see the Income Tax Act’s section 24 and section 25.
3) Add the amount of any pension contributions:
Under Net pay arrangements
Gaining UK tax relief but made to overseas pension schemes
Using Excess relief under net pay provisions
Using relief on making a claim provisions
4) Add the value of employer contributions, which are:
Money Purchase = value of contributions
Defined Benefit = Pension Input Amount minus member contributions (technically you have to add in all pension input amounts and remove the member contributions but this amounts to the same thing and is simpler)
5) Subtract the amount of any taxable lump sum pension death benefit paid to the individual in that tax year
How the taper works
Where both the adjusted income and threshold income have been breached then the rate of reduction in the annual allowance is by £1 for every £2 that the adjusted income exceeds £150,000, up to a maximum reduction of £30,000, down to a minimum tapered annual allowance of £10,000.
This results in an Annual Allowance of £40,000 for those with an adjusted income of less than £150,000; a reducing Annual Allowance for those with adjusted incomes between £150,000 and £210,000 and an Annual Allowance of £10,000 for those with an adjusted income over £210,000.
The Tapered Annual Allowance limits apply to both Defined Contribution and Defined Benefit pension input amounts. Although the value of "contributions" is easily identifiable within Defined Contribution type schemes, it is not as straight forward with Defined Benefit schemes. However, the DB calculation method is explained in the Annual Allowance for pension savings article. When assessing against the above limits it is the combined total of all pension "contributions" that need to be considered. In some circumstances deferred pensions may also count towards the calculation of "contributions".
Those subject to a Tapered Annual Allowance will still be able to carry forward unused allowance from previous tax years.
If clients have breached the tapered annual allowance, also consider if carry forward can be used to reduce or absorb the annual allowance excess amount. Where a Tapered Annual Allowance (TAA) applies in a tax year, it is only the unused TAA amount that can be carried forward from that tax year. Having a nil pension input amount does not mean you carry forward the full standard annual allowance. For high income clients, you still need to work out any TAA limit before you can calculate available carry forward of unused annual allowance.