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Sippchoice: the meaning of ‘contributions paid’

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Before the Upper Tribunal in HMRC v Sippchoice, HMRC successfully argued that its own guidance relating to in specie contributions to registered pension schemes is wrong. The Upper Tribunal held that ‘contributions paid’ means paid in money; it does not encompass a transfer of non-monetary assets, even if made in satisfaction of an earlier obligation to contribute money. The decision fails to address certain fundamental aspects of the registered pension scheme regime, and HMRC’s decision to litigate on this point raises public law issues, questions of legitimate expectation, and the prospect of judicial review.
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