ACA third letter to HMRC on Abolishing the pensions lifetime allowance consultation

We submitted the third wing of our response to the HMRC consultation on Abolishing the pensions lifetime allowance published on 18 July 2023 and the newsletter 152 issued on 20 July 2023.   Following our previous two letters on 17 August (see copy of responses on this page on that date) covering headline policy points, this third letter is a deep dive into the draft legislation so far published to identify remaining issues, either on technical points or areas that appear to demonstrate policy change that ha s not been highlighted.
This confirms our view of the need to delay implementation date, to allow HMRC to release more completely-formed holistic policy and legislation, and to allow time for a technical consultation on it in such a more complete whole.

12 September 2023 - ACA response LTA abolition technical issues - letter 3