UK Director Pension Strategies (2026/27)

Director pension strategy for 2026/27 - employer contributions and Corporation Tax, carry forward, tapered allowance, MPAA, SSAS vs SIPP and pension IHT.

This page is technical reference, not financial advice. Director pension planning sits at the intersection of pensions tax law, Corporation Tax, and estate planning and is reviewed annually by HMRC. Engage a qualified IFA (FCA-regulated), STEP-qualified estate planner, or CTA-qualified tax adviser before executing any strategy on this page, particularly SSAS structures and loanbacks.

1. Overview

A limited-company director extracting profit from an owner-managed business has three tax-efficient wrappers worth using before resorting to high-rate dividend extraction: ISA (£20,000 a year, post-tax money, fully tax-free thereafter), pension (£60,000 standard Annual Allowance plus carry-forward, pre-tax deductible expense to the company, taxed on the way out at marginal rate after 25% tax-free PCLS), and EIS or VCT (front-end Income Tax relief with risk-asset exposure). Of these, the pension wrapper has by far the largest annual capacity for the typical owner-managed company director and is the only one that is deductible at the corporate level.

Director pension planning differs from employee pension planning in three material ways. First, the director controls both sides of the contribution decision: the "employer" (the Ltd company) and the "employee" (the director personally) are essentially the same legal person economically, so the planning question is which side absorbs the tax saving. Second, dividends count towards the tapered AA adjusted-income test and threshold-income test, which catches many directors who assume "dividends do not count for pensions" (they do, for taper). Third, the SSAS structure unlocks two facilities that personal pensions cannot offer: loanback to the sponsoring employer (up to 50% of net asset value), and pooled commercial property purchase typically combined with lease-back of the trading premises.

The remainder of this guide works through the Corporation Tax deductibility test, the three-year carry-forward window, tapered AA mechanics for dividend-heavy directors, MPAA trap, SSAS architecture, SSAS vs SIPP, commercial property purchase, pension vs dividend extraction maths and the disguised remuneration anti-avoidance perimeter. For broader pension mechanics that apply to employees and directors alike, see the pension tax relief guide.

2. Employer pension contributions as a Corporation Tax expense

An employer pension contribution paid by the limited company is deductible against trading profits in the accounting period it is paid, reducing Corporation Tax at the company's marginal rate. Since April 2023 the small profits rate is 19% where profits are no more than £50,000, the main rate of 25% applies to all profits above £250,000, and between the two marginal relief gives an effective marginal rate of 26.5% (the limits fall if there are associated companies). The deduction is governed by HMRC Business Income Manual BIM46035 and the general "wholly and exclusively" test in section 54 Corporation Tax Act 2009.

The wholly and exclusively test. HMRC will allow the deduction only where the total remuneration package (salary + pension + benefits in kind + employer NIC) for the director or other employee is commercially justifiable for the work performed. The test is applied at the level of the package, not the pension contribution alone, so a director earning a market-rate salary plus a £60,000 employer pension contribution is generally fine where the total package reflects an arm's-length remuneration for the role. Spouses paid through the business need genuine documented duties: HMRC will disallow contributions for a "company secretary" spouse with no real involvement and reclassify the payment as a disguised distribution. Children employed through the business (an increasingly common planning lever) face the same scrutiny plus the additional National Minimum Wage and working-time restrictions if under 18.

Timing. The deduction is taken in the accounting period in which the contribution is paid, not accrued. A contribution accrued at year-end but not physically paid until after the period closes goes into the next period's accounts. For owner-managed companies with a 31 March year-end, this means the pension contribution must clear the company bank account on or before 31 March to count against that period's CT. Salary sacrifice arrangements operate through payroll, so the relevant date is when the payroll-generated contribution is paid by the employer to the pension provider, typically within a few days of the payroll run.

Spreading large one-off contributions. Under FA 2004 s.197, relief is spread only where the contributions paid in a period exceed 210% of those paid in the previous period. The excess over 110% of the previous period's contributions is then spread over up to four periods, but only if that excess is £500,000 or more. Most owner-managed company contributions (even £240,000 using the full carry-forward) are therefore deductible in full in the period paid.

Worked example. A single-director consulting company with £200,000 of profit before director remuneration. The director takes a £12,570 salary (no Income Tax or employee NI at the Personal Allowance and Primary Threshold). A company whose only employee is its sole director cannot claim the Employment Allowance, so employer NI is 15% above £5,000: £1,135.50. With a £60,000 employer pension contribution, taxable profit is £126,295 and Corporation Tax is £29,718. Without it, taxable profit would be £186,295 and Corporation Tax £45,618. The contribution therefore saves £15,900 of Corporation Tax, so putting £60,000 into the pension costs the company £44,100. Taken as a dividend instead, the same £60,000 of profit leaves £44,100 after Corporation Tax, or £28,334 after 35.75% higher rate dividend tax. The pension money is taxed later when drawn, so the comparison is between £60,000 in the pension and £28,334 in hand now.

3. Director-level salary sacrifice

Salary sacrifice for a director is mechanically the same arrangement as for any employee: a contractual reduction in gross salary in exchange for an equivalent employer pension contribution. The director signs a formal variation to the service contract (recorded by board minute) agreeing to a lower contractual salary, and the company pays the foregone amount directly to the pension provider. Because the money never reaches the director as salary, it bypasses Income Tax, employee NIC (8% main, 2% above UEL) and employer NIC (15% above the £5,000 Secondary Threshold from April 2025).

Where it makes sense for directors. Salary sacrifice has the biggest impact where the director is taking a meaningful PAYE salary (above the Personal Allowance, typically £50,000+) and would otherwise pay 40% Income Tax plus NIC. For directors on the £12,570 Personal Allowance salary plus dividend strategy (the most common owner-managed setup), sacrifice has limited NIC value because there is little salary above the Primary Threshold to sacrifice; the employer simply pays the pension contribution directly without a sacrifice arrangement. The Corporation Tax deductibility is identical either way.

Employer NI pass-back. Where the director is also the controlling shareholder, the 15% employer NIC saved on a sacrifice arrangement is itself a Ltd-company cash saving. Best practice for owner-managed companies is to pass 100% of the employer NIC saving into the pension pot, since the company has no third-party shareholder interest to balance. Document the pass-back in a board minute or pension contribution policy to evidence the wholly and exclusively test.

Pension contributions and the £100k taper. The Personal Allowance is withdrawn by £1 for every £2 of adjusted net income above £100,000. Salary sacrifice, employer contributions or personal contributions can bring adjusted net income back below £100,000. The same lever works for the £60,000 High Income Child Benefit Charge threshold. Within the taper band each £5,000 that brings income down saves 40% Income Tax on the £5,000 plus 40% on the £2,500 of Personal Allowance restored - £3,000 in all, an effective 60%. Model with the 60% tax trap calculator.

4. Three-year carry-forward of unused AA

Unused Annual Allowance from the previous three tax years can be carried forward. The current year's allowance is used first, then unused allowance from the earliest of the three years. For 2026/27 the carry-forward lookback covers 2023-24, 2024-25 and 2025-26. After 5 April 2027 the 2023-24 allowance permanently drops off, replaced by 2026-27 dropping into the carry-forward window. Carry-forward is automatic - no election or form is required - and uses the AA that was in force in each historic year (£60,000 for all three years in the current window, since the AA was raised from £40,000 to £60,000 in April 2023).

Membership requirement. To use the carry-forward from a given prior year, the individual must have been a member of a UK-registered pension scheme in that year. Mere membership is sufficient - a deferred member of a scheme counts. A director who first joined a pension in 2025-26 can carry forward from 2025-26 only and cannot reach back to 2023-24 or 2024-25 unless they were a member of some other registered scheme in those years, such as an old employer scheme (PTM055100). Directors who have never had a pension start building carry-forward only from the year they join one.

Maximum single-year contribution. Combining a full current £60,000 AA with three prior years of unused £60,000 AA gives a theoretical maximum contribution of £240,000 in one tax year. Employer contributions are not capped by relevant UK earnings (the earnings cap applies only to personal contributions), so the £240,000 can be paid in full from the company as an employer contribution regardless of the director's salary, subject only to the BIM46035 wholly-and-exclusively test on the resulting remuneration package. For business-sale events, one-off bonus realisations or accumulated retained profits in a long-running owner-managed company, this is the cleanest single planning lever in UK personal tax.

Worked example. Director of a consulting Ltd with three years of accumulated retained profits, planning to fully wind down the company in 2028-29 and use BADR. Carry-forward history:

  • 2023-24: pension input £10,000 (workplace only). Unused: £50,000.
  • 2024-25: pension input £15,000. Unused: £45,000.
  • 2025-26: pension input £20,000. Unused: £40,000.
  • 2026-27: current year AA £60,000.

Maximum contribution in 2026/27 = £60,000 + £50,000 + £45,000 + £40,000 = £195,000 gross, paid as an employer contribution from the Ltd company. If the company pays the 25% main rate, the deduction saves £48,750 of Corporation Tax, so the net cost to the company is £146,250. The director's eventual withdrawal will pay marginal-rate Income Tax on 75% of the fund (after 25% tax-free PCLS), so the net effective tax cost on extraction depends on the drawdown rate profile in retirement. Use the pension annual allowance calculator to model carry-forward against actual contribution history.

5. Tapered AA management for dividend-heavy directors

The tapered Annual Allowance reduces the standard £60,000 AA by £1 for every £2 of adjusted income above £260,000, down to a floor of £10,000 at adjusted income of £360,000+. Two tests apply:

  • Threshold income is broadly total taxable income less the individual's own pension contributions. If threshold income is at or below £200,000, no taper applies regardless of adjusted income.
  • Adjusted income is threshold income plus all pension contributions (own + employer + DB accrual). Taper applies only if both gates are crossed: threshold income above £200,000 AND adjusted income above £260,000.

Dividends count both ways. Dividends paid to the director count towards both threshold income and adjusted income (they are taxable income on Self Assessment, even though they are not subject to NIC). This is the single biggest taper-management trap for owner-managed company directors: a director with £150,000 of dividends, £30,000 salary and £60,000 of employer pension contributions has adjusted income of £240,000 and threshold income of £180,000 - comfortably below both gates, no taper. The same director with £180,000 of dividends has threshold income £210,000 (above the £200,000 gate) and adjusted income £270,000 (above £260,000 by £10,000), losing £5,000 of AA. The taper bites silently because dividends are not on a payslip and many directors forget to include them in the AA test.

Mitigation strategies. Three levers are available to a director crossing the threshold:

  • Defer dividends into the following tax year if the company has the cash to hold them. This is by far the cleanest lever - declaring a dividend in early April vs late March moves it to the next year's tests.
  • Increase the director's own pension contribution to reduce threshold income below £200,000, which switches the taper off entirely. A £20,000 personal contribution from a director with £210,000 threshold income drops them to £190,000 and disapplies the taper, restoring the full £60,000 AA.
  • Split income with a spouse who is a genuine director or employee of the company. Spouse dividends are taxable on the spouse, not the director, so they do not count towards the director's AA tests. The transfer of shares must be genuine and the spouse's role documented.

Carry-forward survives the taper. Even when current-year AA is tapered to the £10,000 floor, unused carry-forward from prior years remains usable in the current year. A director tapered to £10,000 in 2026-27 with £50,000 of unused 2023-24 AA can still contribute £60,000 (the tapered £10,000 plus £50,000 from 2023-24). Model with the pension annual allowance calculator.

6. MPAA after flexi-access

The Money Purchase Annual Allowance (MPAA) is a permanent reduction of the AA from £60,000 to £10,000 for defined contribution input, triggered once you flexibly access any DC pot. Taking the 25% PCLS without crystallising any taxable income does NOT trigger MPAA. Buying a standard guaranteed annuity does NOT trigger MPAA. The triggers are: taking taxable income from flexi-access drawdown, taking an Uncrystallised Funds Pension Lump Sum (UFPLS), exceeding the cap on a capped drawdown plan, or buying a flexible annuity.

Director-specific trap. A director semi-retiring from active business but planning to retain some consulting income via the Ltd company is particularly exposed. Drawing £1 of taxable income from a SIPP at age 57 to "test the system" or to use the Personal Allowance permanently caps future DC employer contributions at £10,000 per year, removing the £60,000 contribution headroom that funded the Ltd company strategy in the accumulation phase. The MPAA cannot be reversed. Defer the first flexi-access withdrawal until the Ltd company contribution strategy is fully wound down, or use PCLS-only withdrawals (which do not trigger MPAA) to draw tax-free cash while preserving the AA. Small pension payments of £10,000 or less (PTM063700) also do not trigger the MPAA; there is a limit of three such payments from non-occupational schemes.

7. SSAS basics

A Small Self-Administered Scheme (SSAS) is an occupational pension scheme set up under trust by a limited company and registered with HMRC for tax relief under Part 4 Finance Act 2004. The sponsoring employer is the Ltd company; the members are usually a small number of directors and sometimes family members or other employees, who typically act as trustees. The scheme must have a scheme administrator responsible for HMRC registration, returns and paying scheme tax charges; many SSASs appoint a specialist provider to the role.

Why directors choose SSAS over SIPP. Three structural features distinguish SSAS from a personal SIPP:

  • Loanback. The SSAS can lend up to 50% of its net asset value back to the sponsoring employer at commercial terms (PTM123100). No personal pension or SIPP can lend to a connected party. Loanback is useful for working-capital cycles, asset purchases, or bridging finance where the alternative is a high-rate bank loan.
  • Pooled investment. Member funds inside the SSAS can be pooled for joint investment. Two directors with £200,000 and £300,000 of accumulated pension can jointly buy a £500,000 commercial property. With separate SIPPs they would need a more elaborate co-ownership structure.
  • Employer-connected commercial property. The SSAS can buy the trading premises and lease them back to the sponsoring company at a commercial rent. SIPPs can also buy commercial property but lack the joint-ownership and loanback flexibility around it.

Costs. A SSAS usually costs more to set up and run than a SIPP, because of the trust deed, the scheme administrator and transaction work on property or loans. It tends to make sense where the loan or property facility is the actual planning goal, not just for the tax treatment, which a SIPP provides identically. Compare providers' published charges.

HMRC compliance. The scheme administrator must report certain events to HMRC, keep proper records of loans and property transactions, and pay scheme tax charges. A payment that breaks the rules is an unauthorised payment: the recipient faces a 40% unauthorised payments charge (with a further surcharge in some cases) and the scheme administrator a scheme sanction charge (PTM121000, PTM123200).

8. SSAS vs SIPP

Both SSAS and SIPP are registered DC pension wrappers with identical tax treatment on contributions, growth and withdrawals. The differences are structural and operational:

  • Legal form. SSAS is an occupational scheme (employer-sponsored, trust-based, member-trustees). SIPP is a personal pension (individual contract with a regulated provider).
  • Members. SSAS: usually a small number of directors and family members. SIPP: one member per contract.
  • Loanback to employer. SSAS: yes, up to 50% NAV at commercial terms. SIPP: no (loanbacks to connected parties are unauthorised payments).
  • Pooled investment. SSAS: yes - all members' funds in one pool. SIPP: each pot is segregated.
  • Investment universe. Both can hold UK shares, ETFs, funds, commercial property, gold, and most assets except residential property and "taxable property" (eg fine art, classic cars). SSAS has slightly more flexibility on unlisted shares of connected companies (still restricted but possible at arm's length).
  • Borrowing. Both can borrow up to 50% of net asset value to fund investments (typically commercial property).
  • Cost. SSAS: usually higher set-up and running costs. SIPP: often lower, with platform and dealing charges. Compare providers' published charges.
  • Regulator. SSAS: The Pensions Regulator (TPR). SIPP: Financial Conduct Authority (FCA).
  • Best fit. SSAS: owner-managed Ltd company directors wanting loanback or pooled property. SIPP: individuals wanting broad investment choice with no connected-party facilities.

Choosing. For a single director with no property or loanback plans and no spouse on the payroll, a low-cost SIPP (Vanguard, InvestEngine, AJ Bell, Hargreaves Lansdown) is operationally simpler and cheaper. SSAS earns its higher costs when the loanback facility is genuinely used (eg cyclical working capital cycles, equipment financing, bridging) or when a commercial property purchase is being jointly funded with a co-director or spouse. Many directors run both: a SIPP for liquid market investments and a SSAS holding the trading premises.

9. Commercial property in SSAS

The classic SSAS commercial property structure is to buy the trading premises (office, workshop, warehouse, retail unit) through the SSAS and lease them back to the sponsoring Ltd company at a commercial market rent. This delivers three simultaneous tax benefits:

  • The rent paid by the Ltd company is a tax-deductible trading expense, as it would be if paid to any landlord.
  • The rent received by the SSAS grows tax-free inside the pension wrapper - no Income Tax, no Corporation Tax on the pension's income.
  • Capital appreciation of the property accrues tax-free inside the SSAS - no Capital Gains Tax on eventual sale.

Mechanics. The SSAS members (directors) transfer in existing pension pots and / or make fresh employer contributions until the SSAS has the cash to buy. The SSAS can borrow up to 50% of net asset value to top up the purchase price (a £400,000 SSAS can buy up to £600,000 of property with £200,000 of borrowing). The rent should be a commercial market rent, usually supported by an independent valuation. The Ltd company signs a formal commercial lease with the SSAS as landlord. The rent must actually be paid; failure triggers HMRC scrutiny.

Residential property is banned. Residential property is taxable property for an investment-regulated scheme such as a SSAS or SIPP. Acquiring it, directly or indirectly, creates an unauthorised payments charge on the member, and the scheme administrator is liable to a scheme sanction charge on the income and gains from it (PTM125200). Limited exceptions exist, such as some job-related accommodation.

Worked example. Owner-managed consulting Ltd renting office space at £30,000 a year from a third-party landlord. After a few years of profitable trading the director has accumulated £350,000 in their SIPP. They transfer it into a newly-established SSAS and buy a £500,000 office unit for the trading company, using £150,000 of SSAS borrowing to top up the purchase. The Ltd company now pays £30,000 a year of rent to the SSAS instead of to the third-party landlord; it remains deductible for Corporation Tax as before. The £30,000 is received by the SSAS free of tax, paying down the borrowing and adding to the pension fund. Capital growth on the £500,000 unit over 20 years (say doubling to £1,000,000) accrues tax-free inside the SSAS, ready to be drawn at retirement at 25% PCLS + drawdown rates. Compared with personal ownership, the rent is not taxed as the director's income and there is no CGT on a sale by the scheme, while the trading company still deducts the rent. The catch: liquidity is locked until the normal minimum pension age (55, rising to 57 from 6 April 2028) and the property cannot be sold without a willing buyer.

Costs and gotchas. Stamp Duty Land Tax applies to a purchase in England or Northern Ireland at the non-residential rates: 0% up to £150,000, 2% on the next £100,000 and 5% above £250,000, so £14,500 on a £500,000 unit (per GOV.UK). Legal, valuation and administration fees are extra. The structure is tax-efficient but operationally heavier than buying funds.

10. Pension vs dividend extraction

The headline question for owner-managed company directors is whether to extract surplus profit as dividend (immediate cash, taxed at 10.75% basic / 35.75% higher / 39.35% additional dividend rate) or as employer pension contribution (deferred cash, deductible against CT today, taxed at marginal Income Tax on withdrawal, normally from age 55 rising to 57 from 6 April 2028, with 25% usually tax-free).

Pension usually wins up to the AA. Take £60,000 of profit in a company paying the 25% main rate. As an employer contribution, all £60,000 goes into the pension (a net cost of £45,000 after Corporation Tax relief). As a dividend, Corporation Tax leaves £45,000, and 35.75% higher rate dividend tax leaves £28,913 in the director's hands. Even after Income Tax at drawdown - 25% tax-free and the rest at 40% - the pension gives £42,000, or £51,000 if the rest is taxed at 20%, before any years of tax-free investment growth.

Dividend wins on liquidity and short horizon. Pensions cannot normally be drawn before age 55 (rising to 57 from 6 April 2028). A director who needs cash now - for a house deposit, school fees or investment outside the pension - needs salary or dividends. For a director who expects to pay 40% or 45% Income Tax in retirement (for example with a large defined benefit pension already in payment), the pension's advantage narrows.

Mixed strategy is usually optimal. Most owner-managed company directors use a mixed-extraction strategy: low PAYE salary (typically Personal Allowance £12,570 or Secondary Threshold £5,000 depending on NIC optimisation), employer pension contribution up to the available AA including carry-forward, then dividends for whatever spendable cash is needed beyond the salary. Use the salary vs dividend calculator to model the optimal salary level and the dividend tax calculator for the remaining dividend slice.

11. Death benefits and the April 2027 IHT change

DC pension funds are currently outside the Inheritance Tax estate, which has made pensions a powerful estate planning vehicle. Death before age 75 allows the entire undrawn fund to pass to nominated beneficiaries as drawdown or lump sum with no Income Tax (lump sums are subject to the Lump Sum and Death Benefit Allowance, £1,073,100 for most people). Death after age 75 keeps the fund outside the estate for IHT but the beneficiary pays Income Tax at their marginal rate on any withdrawal.

April 2027 change. Autumn Budget 2024 announced that from 6 April 2027 most unused pension funds and death benefits will be included in the estate for IHT, at the standard 40% rate above the available nil-rate bands. The change is legislated in the Finance Act 2026. Death-in-service benefits from registered schemes are excluded, and personal representatives are liable to report and pay the tax (per the consultation outcome). The current Income Tax treatment continues separately, which means a beneficiary inheriting a pension on a death after age 75 may pay both 40% IHT (post-2027) on the fund AND marginal Income Tax (up to 45%) on the eventual withdrawal, giving a combined effective tax rate of up to 67% in the worst case.

What it means for directors. Directors with substantial pension pots (£500,000+) who were treating pension as an inter-generational wealth transfer vehicle need to reassess before April 2027. The remaining estate-planning advantages of pension are still meaningful: tax-free investment growth, the 25% tax-free PCLS, the death-before-75 Income Tax exemption on beneficiary withdrawal. But the IHT shelter element is being closed. Alternative planning routes (life assurance written in trust, gifting outside the 7-year window with the 7-year gift taper calculator, Business Relief on trading company shares) are gaining relative attractiveness. Engage a STEP-qualified estate planner before making strategy changes.

12. Anti-avoidance: disguised remuneration

HMRC has invested heavily in anti-avoidance rules around remuneration since the early 2010s, and pension-adjacent arrangements that look like tax-avoidance vehicles attract close scrutiny. The principal regime is Part 7A of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA), which charges PAYE Income Tax and NICs on "relevant steps" taken by a third party (typically a trust or offshore structure) in connection with an employee's earnings. The loan charge introduced by the Finance (No. 2) Act 2017 applied on 5 April 2019 to outstanding disguised remuneration loans; after the 2019 independent review it applies only to loans made on or after 9 December 2010 (per GOV.UK).

What is safe. Contributions to a genuine HMRC-registered UK pension scheme (workplace DC, SIPP, SSAS) made by the employer in respect of an employee or director are explicitly carved out of the disguised remuneration rules. The wholly and exclusively test in BIM46035 governs CT deductibility but the Part 7A charge does not apply. SSAS structures that satisfy the standard loanback and property rules in PTM123100 and the wider Pensions Tax Manual are authorised. Pension recycling (using a PCLS to fund significantly increased contributions) is its own anti-avoidance rule under PTM133810 and is separate from Part 7A.

What is risky. Employer-financed retirement benefit schemes (EFRBS), unfunded unapproved retirement benefit schemes (UURBS), contractor loan arrangements, offshore trusts paying out as "loans" that are not realistically repayable, and non-UK pension schemes that fail the HMRC Recognised Overseas Pension Scheme conditions are all vulnerable to disguised remuneration challenges. Directors offered such arrangements - typically marketed as "tax-efficient" alternatives to a SSAS or SIPP - should treat them as high-risk and seek independent tax advice before participating. HMRC publishes a specific guidance page on disguised remuneration for owner-managed companies that should be the first reading before considering any non-standard structure.

Cross-references and modelling tools across the SalaryTax director-extraction stack:

Frequently asked questions

How much can a Ltd company director contribute to a pension?

An owner-managed company can pay an employer pension contribution up to the director's available Annual Allowance for the tax year, which is £60,000 standard in 2026/27 plus any unused allowance carried forward from the previous three years (a theoretical £240,000 maximum). Employer contributions are not capped by relevant UK earnings, so a director on a £12,570 PAYE salary can still receive a £60,000 employer contribution. For the contribution to be deductible against Corporation Tax it must satisfy the HMRC "wholly and exclusively" test under BIM46035, meaning the total remuneration package (salary plus pension plus benefits) must be commercially justifiable for the work performed. Spouses on the company payroll need genuine duties documented or HMRC will disallow the deduction.

Are employer pension contributions deductible against Corporation Tax?

Yes, provided the wholly and exclusively rule in BIM46035 is met. An employer pension contribution paid in the accounting period reduces taxable profits by the contribution amount, saving Corporation Tax at the company's marginal rate: 19% where profits are no more than £50,000, 26.5% on profits in the marginal relief band up to £250,000, and 25% on all profits above £250,000 (the limits are lower with associated companies). Section 196 of the Finance Act 2004 gives relief for contributions in the period in which they are paid. Under s.197, relief is spread over later periods only where contributions exceed 210% of the previous period's and the excess over 110% is £500,000 or more.

What is the tapered Annual Allowance and how do dividends affect it?

The tapered Annual Allowance reduces a director's £60,000 standard AA by £1 for every £2 of adjusted income above £260,000, down to a floor of £10,000 at adjusted income of £360,000 or more. Adjusted income includes salary, taxable benefits, employer pension contributions and dividend income. Threshold income (broadly total taxable income less the director's own pension contributions) must also exceed £200,000 for the taper to bite. Dividends count towards both threshold and adjusted income, which means a director taking £150,000 in dividends plus a £30,000 salary plus a £60,000 employer pension contribution has adjusted income around £240,000 and is below the taper - but the same director with £180,000 of dividends would cross £260,000 and lose AA.

What is a SSAS and how does it differ from a SIPP?

A Small Self-Administered Scheme (SSAS) is an occupational pension scheme set up by a limited company, with the directors typically acting as both members and trustees. It is registered with HMRC for tax relief and regulated by The Pensions Regulator. A SIPP (Self-Invested Personal Pension) is an individual personal pension wrapper. The key differences: a SSAS can lend up to 50% of net asset value back to the sponsoring employer (loanback), can pool member funds for joint investment, and can hold trustee-borrowed commercial property. A SIPP cannot make loanbacks to a connected company and each member's pot is segregated. A SSAS usually costs more to set up and run than a SIPP, so it tends to suit cases where a loan to the company or a jointly funded property purchase is the actual goal.

Can a SSAS lend money to the sponsoring company?

Yes. Finance Act 2004 s.179 and Schedule 30 allow an occupational scheme to lend to a sponsoring employer if five tests are met (PTM123200): the loan is at most 50% of the scheme's cash and net assets immediately before it is made; it is repaid within 5 years; interest is at least the prescribed rate (1% above the average base rate of six named banks, rounded up to the nearest 0.25%); it is repaid in at least equal annual instalments of capital and interest; and it is secured throughout by a first charge on an asset of at least the loan's value. A loan can be rolled over once, for example where the employer is in genuine financial difficulty. A failed test creates an unauthorised payment, with a 40% unauthorised payments charge on the company and a scheme sanction charge on the scheme administrator.

Can a SSAS or SIPP buy commercial property?

Yes, both wrappers can hold UK commercial property directly, and SSAS can buy property jointly with other members or with the sponsoring employer. The classic strategy is to use the pension to buy the trading premises and then lease them back to the company at a commercial market rent. The rent paid by the company is a deductible Corporation Tax expense, as rent to any landlord would be, while the rent received by the SSAS or SIPP is free of tax inside the pension. Capital growth on the property is also tax-free. The pension can borrow up to 50% of net asset value to fund the purchase. Residential property is taxable property: acquiring it creates an unauthorised payments charge on the member and a scheme sanction charge on the scheme administrator (PTM125200). The lease should be on commercial terms at a market rent, usually supported by an independent valuation.

Is pension better than dividends for extracting profit from a Ltd company?

Within the Annual Allowance, an employer contribution usually beats a dividend for money the director does not need yet. At the 25% main rate, a £60,000 employer contribution costs the company £45,000 after Corporation Tax relief. The same £60,000 of profit taken as a dividend becomes £45,000 after Corporation Tax, and £28,913 after 35.75% higher rate dividend tax (£27,293 at 39.35%). The pension is taxed when drawn: with 25% tax-free and the rest taxed at 40%, the £60,000 gives £42,000, or £51,000 at 20%, before any investment growth. The trade-off is access: pensions cannot normally be drawn before age 55 (rising to 57 from 6 April 2028).

Do employer pension contributions count against the tapered AA?

Yes. Employer contributions are included in both the pension input total counted against the Annual Allowance and the adjusted income figure used to test the taper. This is critical for directors: a strategy of "keep salary low, take the rest in dividends, plus a £60k employer pension contribution" can push a director with substantial dividends into the taper because the £60k employer contribution adds to adjusted income on top of the dividends. The way out is to keep total adjusted income below £260,000 (so the taper does not apply) or to reduce threshold income to £200,000 or less, for example by deferring dividends or making personal contributions, so the taper does not apply at all.

Are pensions inside or outside the Inheritance Tax estate?

Defined contribution pension pots are currently outside the Inheritance Tax estate, but this changes from 6 April 2027, as announced at Autumn Budget 2024 and legislated in the Finance Act 2026. From that date most unused pension funds and death benefits are included in the estate for IHT, at the standard 40% rate above the available nil-rate bands; death-in-service benefits from registered schemes are excluded, and personal representatives are liable to report and pay the tax. Death before age 75 still allows benefits to be paid free of Income Tax to beneficiaries, but IHT may now apply. Death after age 75 already triggers Income Tax at the beneficiary's marginal rate on any withdrawal, so post-2027 the combined IHT plus Income Tax effective rate on death-after-75 inherited pensions can reach 67% in the worst case. Directors with substantial pots should reassess pension vs Individual Savings Account (ISA) vs other wrappers before April 2027.

What is disguised remuneration and how does HMRC police it?

Disguised remuneration is HMRC's catch-all term for arrangements that route reward through a third party (often a trust or offshore structure) to avoid PAYE Income Tax and NICs on what would otherwise be ordinary employment income. The Part 7A ITEPA 2003 charging rules treat third-party payments to or for the benefit of an employee as employment income subject to PAYE in the period of the relevant step. Pension contributions made under genuine HMRC-registered schemes are explicitly carved out as authorised, but contrived arrangements using EBT loans, employer-financed retirement benefit schemes (EFRBS), or non-UK pensions that fail the HMRC overseas pension scheme conditions are vulnerable to challenge. The loan charge, which applied on 5 April 2019 to outstanding disguised remuneration loans, was limited after the 2019 independent review to loans made on or after 9 December 2010. Genuine SSAS and SIPP contributions paid by the sponsoring employer are not at risk; the risk is in artificial structures.

When does carry-forward expire?

Carry-forward of unused Annual Allowance lapses at the end of the fourth tax year. In 2026/27 (2026-27) you can use unused allowance from 2023-24, 2024-25 and 2025-26. The allowance from 2023-24 will permanently drop off at the end of 5 April 2027. Carry-forward is used in chronological order: current year first, then oldest carry-forward year, then next oldest, then most recent. Membership of a UK-registered pension scheme in each carry-forward year is required (mere membership is enough - no minimum contribution). A director planning a large one-off employer contribution following a business sale, dividend, or windfall should check carry-forward eligibility before the relevant year-end as the unused allowance is "use it or lose it".

Does the MPAA affect employer contributions from my Ltd company?

Yes. The Money Purchase Annual Allowance of £10,000 caps the combined total of all defined contribution pension input including employer contributions, once you have flexibly accessed any DC pension pot. A director who triggers MPAA by taking taxable income from a SIPP cannot then accept more than £10,000 a year of employer contributions into any DC scheme (including a SSAS holding only money market assets) without an AA tax charge. This is the single biggest planning trap for directors approaching semi-retirement: taking £1 of taxable drawdown to "test" the system permanently restricts the DC contribution headroom for any future re-engagement with the business. Defined benefit accrual outside the MPAA still uses the residual £50,000 alternative AA, but pure-DC SSAS and SIPP arrangements lose the headroom permanently.

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