An explanation of the money purchase annual allowance

Anyone taking income from a flexi-access drawdown plan or using an uncrystallised funds pension lump sum will trigger the money purchase annual allowance of £4,000.

For those who are lucky enough to have a final salary scheme the full £40,000 annual allowance may still apply. Remember individuals with high earnings may be caught by the tapered annual allowance and have an annual allowance below £40,000.

On 6 April 2017 the money purchase annual allowance reduced from £10,000 to £4,000. However, this only became law on 16 November 2017 when the Finance Act (No.2) 2017 received Royal Assent.

What triggers the money purchase annual allowance?

Mainly the two events mentioned above.

But an individual in capped drawdown who either chooses to convert to flexi-access drawdown or exceeds their existing Government Actuary's Department income limits will also trigger it. 

Action	Trigger
Take pension commencement lump sum only - no income from flexi-access drawdown
Take pension commencement lump sum only and income from flexi-access drawdown
Take uncrystallised funds pension lump sum
Remain in capped drawdown
Exceed Government Actuary's Department limit in capped drawdown
Take annuity	1
Take 'small pot'

¹If the amount of annuity can reduce, or it is a short term annuity in a capped drawdown plan that's over the Government Actuary's Department limit, the money purchase annual allowance will be triggered.  Any other type of annuity won't trigger the money purchase annual allowance.

When does it apply?

The money purchase annual allowance applies to all defined contribution savings made by that individual after the date it's triggered. If this occurs part-way through a pension input period only the contributions made after the trigger are tested against the money purchase annual allowance. However, the total contributions/accrual in that tax year are also tested against the £40,000 annual allowance or tapered annual allowance.

For the avoidance of doubt, this includes contributions made to any other defined contribution plans the individual has in addition to the one they've taken benefits from.

What about DB?

Accrual under defined benefits schemes is not tested against the money purchase annual allowance, but will be included in the test of total contributions against the annual allowance/tapered annual allowance:

An alternative annual allowance of £36,000 applies to the defined benefit savings but is only required where the annual allowance is exceed.

What about carry forward?

It's not possible to carry forward unused tax relief against the money purchase annual allowance. Defined contribution contributions must be limited to £4,000 to avoid an annual allowance tax charge.

It is however possible to carry forward unused relief against the full annual allowance if it still applies:

If defined contribution contributions exceed the money purchase annual allowance a tax charge will be due.

The default chargeable amount is the excess over the annual allowance. However, there is also a second test for the alternative chargeable amount to ensure the excess defined contribution contributions are not simply offset against defined benefit savings. This is the excess over the money purchase annual allowance added to the excess over the alternative annual allowance of £36,000.  The taxable amount is the higher of the two calculations:

Do I have to tell anyone I’ve triggered the MPAA?

Where an individual has flexibly accessed their benefits under a scheme, they will receive a flexible access statement. They are required to notify schemes where they are still actively accruing benefits, they have flexibly accessed their benefits. This can be done by sending a copy of the statement.

When to they have to tell them?

They must, within, 13 weeks:

• give the scheme administrator or scheme manager a copy of the flexible access statement or
• tell the scheme administrator or scheme manager they have received a flexible access statement, and either the date of the relevant event or, where applicable, that the relevant event occurred more than two years before the start of the relevant 13-week period.

In addition if they become a member of another registered pension scheme after the start of their 13-week notification period, then within 91 days beginning with the date they became an accruing member, they must also tell that scheme they have flexibly access their benefits.

What is an accruing member?

For a money purchase plan this means contributions are being made by the individual, their employer or somebody on behalf of the individual.

For a cash balance or hybrid plan there is currently an arrangement for the accrual of benefits in respect of the individual under the arrangement.

Are there any exceptions?

The individual does not need to do this if they joined the new scheme as a result of a recognised transfer from another registered pension scheme, QROPS or former QROPS after the date of the relevant event and no contributions are being paid.

The individual also does not have to pass on information about receiving a flexible access statement to a scheme administrator if they have already told them they have flexibly accessed their pension.

Further information

• HMRC Pensions Tax Manual - PTM056500: Annual allowance: money purchase annual allowance
• HMRC Pensions Tax Manual - PTM166400 - Information and administration: information requirements when a member flexibly accesses their benefits: action a member must take if they receive a flexible access statement

Note

The information provided is based on our current understanding of the relevant legislation and regulations and may be subject to alteration as a result of changes in legislation or practice. Also it may not reflect the options available under a specific product which may not be as wide as legislations and regulations allow.

All references to taxation are based on our understanding of current taxation law and practice and may be affected by future changes in legislation and the individual circumstances of the investor.