Where the arrangement under which an employer’s asset-backed pension contribution is made is an acceptable structured finance arrangement (see ¶377-080, ¶377-100 and ¶377-120) and therefore relief for the pension contribution is not denied, that relief may nevertheless be ‘clawed back’ if, subsequently, there is a change in the ‘lender’s position’ as originally expressed in the terms of the arrangement, events which should have occurred fail to do so or events occur which should not have done.

In their guidance on this topic, HMRC give examples of such changes and events;

payments or drawings which fail to be made;

Want to read more?

This content requires a Croner-i Tax and Accounting subscription.

Existing subscriber? Log in

No subscription?

Contact us to discuss your requirements.