The tax regime for unregistered pension plans is significantly less attractive and substantially more complex as a result of employer financed retirement benefits schemes (EFRBS) falling within the scope of the disguised remuneration provisions. Greater sophistication will be required with the delivery of top-up pensions if tax efficiency is to be achieved in a manner consistent with the detail and policy of the tax legislation. In practice, this is likely to require the use of unfunded promises to pay pension through structures using security.
