In B Youngman v HMRC [2017] UKFTT 893 (19 December 2017) the FTT reinstated an appeal in circumstances where HMRC would not give an undertaking to reconsider the taxpayer’s circumstances.
Mr Youngman had been a partner at E&Y until his retirement in June 1992. He had contributed to the E&Y pension scheme and the trustees had decided to wind the scheme down in 2008.
On A-day (6 April 2006) the ‘lifetime allowance charge’ had been introduced (FA 2004 s 215). The charge arises if there is a ‘benefit crystallisation event’; i.e. benefits are taken or start to be taken by the person for whose benefit a pension scheme was established and the amount crystallised exceeds the person’s ‘lifetime allowance’. FA 2004 Sch 36 provided various protections and so did FA 2011 Sch 18 which reduced the lifetime allowance. The details of these protections were...
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