TAXATION AND TRUSTS

 

A failed claim for the non-residential rate of stamp duty land tax to apply

(AF1, ER1, LP2, RO3)

A case where the Upper Tax Tribunal decided a taxpayer could not go back and make a late claim for multiple dwellings relief after his claim for the non-residential rate of stamp duty land tax to apply had failed.

 

The case was HMRC v Ridgway (2024 UKUT 00036), in which the taxpayer paid £6.5 million for a property comprising two separate titles. One was a semi-detached house and gardens. The other an adjoining plot with separate access and a building, known as the Old Summer House, previously used as a garage and later as an artist’s studio.

 

Two weeks prior to completion, at the instigation of Mr Ridgway, the vendors granted a commercial lease of the Old Summer House for a term of six months to a photographic studio business called Vine House Studios. Mr Ridgway had identified Vine House Studios as a potential commercial user of the Old Summer House. The lease contained a covenant that the Old Summer House should not be used for residential purposes.

 

Mixed-property purchases are broadly subject to Stamp duty land tax (SDLT) at the lower non-residential rates of SDLT. Please see: Stamp Duty Land Tax: Rates for non-residential and mixed land and property.

 

 

Mr Ridgway submitted a land transaction return on 1 September 2017 in which it was stated that the property was mixed use, part residential and part commercial, on the basis that the garage was in commercial use at the time of the sale, because he had invited the sellers to grant a six-month commercial lease to a photographic studio business. SDLT of £314,500 was paid at the lower non-residential rate. If SDLT had been paid at the residential rate it would have amounted to £888,750, so this claim would have saved him SDLT of £574,250.

 

However, HMRC rejected his claim, because it was “suitable for use as a dwelling”. The land transaction return was therefore amended to charge SDLT at the residential rate. Mr Ridgway's subsequent appeal to the First-tier Tax Tribunal (FTT) that the Old Summer House was not residential property was also rejected on the basis that the property was suitable for use as a dwelling, and that the grant of the lease brought it under the scope of the stamp duty anti-avoidance provisions.

 

Mr Ridgway had also appealed against the amendment to his land transaction return on the basis that, if the Old Summer House was residential property, then he ought to be entitled to multiple dwellings relief pursuant to section 58D and Schedule 6B FA 2003.

Where multiple dwellings relief is claimed, tax for the dwellings is calculated by taking the average paid for a dwelling and then multiplying the tax due on that amount by the number of dwellings. Please see Stamp Duty Land Tax relief for land or property transactions.

 

With the benefit of multiple dwellings relief, the SDLT would have amounted to £577,500, so this claim would have saved him £311,250.

 

The FTT agreed that multiple dwellings relief was available in relation to the notional transaction because the requirements of Schedule 6B were satisfied. The effect of these findings was that the FTT allowed the appeal in part, with SDLT to be calculated at the residential rate but with the benefit of multiple dwellings relief. However, HMRC appealed to the Upper Tribunal.

 

And, because by the time his mixed-use claim had been rejected, he was past the time limit to claim multiple dwellings relief, Mr Ridgway appealed to the Upper Tax Tribunal, challenging the FTT's decision that SDLT was payable at the non-residential rate, and that, alternatively, the FTT was right to find that multiple dwellings relief was available. He also requested permission to make an out-of-time claim for multiple dwellings relief.

 

He has now lost on both counts. The Upper Tribunal agreed with the FTT on residential use, but decided that the FTT was wrong to allow the appeal in part and reduce the self-assessment by reference to multiple dwellings relief, as there was no provision for Mr Ridgway to make an out of time claim for multiple dwellings relief. It said:

 

“We accept that HMRC's position might be said to give rise to unfairness to taxpayers in the position of Mr Ridgway…”

 

Citing the England and Wales Court of Appeal’s ruling in Candy v HMRC (2022 EWCA Civ 1447), it added:

 

“SDLT is a self-assessed tax which imposes hard-edged deadlines. Where a relief requires a claim, and a claim is not made in accordance with any procedural requirements, the taxpayer will not be entitled to relief. In the present context, section 58D(2) is clear that relief “must” be claimed in a return or an amended return. The relevant facts were known to Mr Ridgway at the time he made his return. He made an error in concluding that the Property was non-residential property. The absence of any provision for Mr Ridgway to make a claim out of time or during the course of an enquiry is consistent with the benefit of certainty and finality referred to by the Court of Appeal in Candy.”

 

Comment

 

This case highlights the difficult position where taxpayers in the position of Mr Ridgway may be encouraged to forgo the correct SDLT treatment to ensure that they at least have the benefit of multiple dwellings relief. If HMRC were to challenge the availability of multiple dwellings relief, the taxpayer could still assert that the non-residential rate should apply because that would not require a claim.

 

As the Upper Tribunal stated in this case: “…Mr Ridgway was not overcharged by the self-assessment in the amended return because the self-assessment charged the right amount of tax, taking into account that Mr Ridgway had made no claim to multiple dwellings relief and where there was no obligation on HMRC to give effect to the relief in the absence of a claim.”

 

 

HMRC withdraws advance assurance on redundancy payments (AF1, RO3)

HMRC’s announcement that it is no longer going to provide employers and their advisers with advance assurance on the tax treatment of termination and redundancy payments was made in the February HMRC Employer Bulletin.

 

Under current guidance, HMRC is committed to giving a binding answer if a company makes enquiries on termination cases involving: how the £30,000 threshold applies to termination payments; non-cash provisions; the disability and injury compensation exception; and the foreign service exception.

 

Going forward, HMRC will no longer give a binding answer on these cases, outside the normal non-statutory clearance process, for example, where there is a genuine point of uncertainty on the correct treatment.

 

If employers or advisers have a “genuine point of uncertainty” on the tax and National Insurance treatment of a termination payment they should use the Non-Statutory Clearance Service.

 

It takes up to 28 days for HMRC to reply “unless there are any complicated issues involved”. If the enquiry is complex, HMRC will acknowledge the non-statutory clearance service request and adds that it will, if possible, tell the employer/adviser when to expect a full reply. If this is not possible, HMRC will contact them when it is able to tell them when they can expect a full reply.

 

Previously, HMRC guidance stated that the tax authority would assist taxpayers if they required an explanation of how the following statements of practice and extra statutory concessions operated within the context of a termination case: SP2/81: contributions made to a pension scheme as part of termination arrangements; SP10/81: the meaning of disability; SP13/91: voluntary payments on retirement made before 6 April 2006; SP1/94: clearance procedure for redundancy schemes; ESC A10: lump sums from overseas pension schemes; and ESC A81: legal expenses in termination settlements. Queries on these should now be dealt with in the same way, through the Non-Statutory Clearance Service.

 

This means that enquiries about contributions made to a pension scheme as part of termination arrangements, clearance procedures for redundancy schemes, lump sums from overseas pension schemes and legal expenses in termination settlements, will all have to go through the non-statutory clearance service.

 

 

 

 

 

 

HMRC’s manual say:

 

“It’s vital to identify redundancy payments properly because:

 

• what people call redundancy payments may not be within the special definition of redundancy in EIM13800
• redundancy usually involves other payments being made as well as those for the redundancy itself. For example payments in lieu of notice are often made at the same time (see EIM12975). Consider the whole package of payments and benefits under EIM12810 to make sure that no other charges are missed.”

 

Please also see EIM12800 Termination payments and benefits — contents and EIM12820 — Termination payments and benefits.

 

 

Marriage allowance: new claims process

(AF1, RO3)

A recent update from HMRC on the marriage allowance transfer claim form (MATCF).  As a reminder, the marriage allowance allows married couples/civil partners, born after April 1935, to transfer 10% of their personal allowance if one partner earns an income below their personal allowance of £12,570 and the other partner is a basic rate taxpayer.

 

So, an individual can transfer £1,260 of their personal allowance to their higher-earning partner, to reduce the amount of tax they pay. This means couples can reduce the income tax they pay by up to £252 (i.e. £1,260 x 20%).

 

According to HMRC’s latest Agent Update, the new MATCF form is available to view now.

 

All agents submitting a MATCF repayment claim on behalf of their clients, and who are wanting to receive the repayment directly, will need to use the new form from 26 February 2024. The new form can be found on Apply for Marriage Allowance by post.

 

HMRC says that the previous versions of the MATCF claim form should have been used until the new version went live on 26 February 2024. Any new forms dated and submitted to HMRC before 26 February 2024 will be rejected.

 

HMRC has also warned that, from 26 February 2024 onwards, form MATCF needs to be submitted on paper to HMRC exactly as it prints out on GOV.UK. The form should not be amended or changed. However, HMRC has added that,

 

“…if it is absolutely essential for your internal processes (for example, you need to add a company logo or bar code reference to the form to connect it to your own systems) you may replicate, print and submit the form. You can only make changes in the white space at the top of the form. Any other changes or additions outside of the white space at the top of the form will result in the claim being rejected and returned to the agent, who will need to submit again using the correct format.”

 

 

The updated claim form includes:

 

• a question to ask if the taxpayer is nominating a professional that charges a fee for their services to act on their behalf;
• a space to capture the nominated agent’s Agent Reference Number (if an agent is acting on behalf of a client).

 

From 26 February 2024, anyone making a claim on behalf of others, or wanting to receive a repayment on behalf of their client, will need to provide their Agent Reference Number when submitting a MATCF form. There is a required field to complete the Agent Reference Number. Failure to add the Agent Reference Number to the designated nomination section on or after 26 February 2024 will result in repayments for valid claims being paid directly to the taxpayer, not the nominated third party.

 

Clients will also need to have completed the section which informs HMRC whether they are nominating a professional to act on their behalf for the purposes of the repayment claim. Failure to select ‘Yes’ or ‘No’ in the appropriate section could also result in repayments for valid claims being paid directly to the taxpayer, not the nominated third party.

 

This is all part of an effort by HMRC to prevent taxpayers from being charged excessive fees to obtain small tax repayment claims. Similar changes also apply to claims for a tax refund for work related expenses, using form P87. Please see: Claim tax relief for your job expenses if you cannot claim online.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

INVESTMENT PLANNING

House price growth increases in February

(ER1, LP2, RO7)

 

Nationwide’s latest monthly house price index. It shows that annual house price growth returned to positive territory for first time in over a year in February and that house prices rose month on month in February.

 

The annual rate of change returned to positive territory for the first time since January 2023, with prices up 1.2% year on year. And UK house prices rose 0.7% month on month in February. Prices were up month-on-month, after taking account of seasonal effects. The price of a typical UK home (not seasonally adjusted) increased to £260,420:

 

Headlines	Feb-24	Jan-24
Monthly index*	525.6	521.9
Monthly change*	+0.7%	+0.7%
Annual change	+1.2%	-0.2%
Average price (not seasonally adjusted)	£260,420	£257,656

 

*Seasonally adjusted figure (note that monthly % changes are revised when seasonal adjustment factors are re-estimated).

 

Commenting on the figures, Robert Gardner, Nationwide's Chief Economist, said:

 

“House prices are now around 3% below the all-time highs recorded in the summer of 2022, after taking account of seasonal effects.”

 

“The decline in borrowing costs around the turn of the year appears to have prompted an uptick in the housing market. Indeed, industry data sources point to a noticeable increase in mortgage applications at the start of the year, while surveyors also reported a rise in new buyer enquiries.”

 

“Nevertheless, near-term prospects remain highly uncertain, in part due to ongoing uncertainty about the future path of interest rates. After falling sharply in late December, swap rates, which underpin fixed rate mortgage pricing, have drifted back up (see chart).”

 

“Borrowing costs remain well below the highs recorded last summer but, if the recent upward trend is sustained, it threatens to restrain the pace of any housing market recovery.”

 

“While the squeeze on household budgets is easing, with wage growth now outstripping inflation by a healthy margin, it will take time to make up for the ground lost over the past few years, especially given consumer confidence remains fragile.”

 

You can read the full Nationwide report here.

 

Comment

 

For those whose home is their prime asset, effective planning may be needed to reduce or provide for inheritance tax (IHT). The residence nil rate band (RNRB) will provide a solution for many married couples/civil partners with children, grandchildren or other lineal descendants. However, careful consideration should be given to its use in planning and the fact that it is reduced by £1 for every £2 where the deceased’s estate exceeds £2 million.

 

For those clients for whom the problem will remain, the answer may be provision for the liability through life assurance (joint lives last survivor for married couples/civil partners) in trust to those who will suffer because of the payment of the IHT.

 

 

 

 

 

 

Bank of England Money and Credit - January 2024

(AF4, FA7, LP2, RO2)

 

The Bank of England (BoE) has published its latest Money and Credit report. Some of the main highlights include:

 

• Households deposited, on net, £6.8bn with banks and building societies in January, compared with £5.4bn in December. Flows into sight deposits, of £7.2bn, were higher than flows into time deposits, of £0.1bn. The flows into interest-bearing sight deposits were partly offset by net outflows from non-interest bearing accounts of £4.1bn. (Time deposits pay a fixed rate of interest until a given maturity date. Funds placed in a time deposit usually cannot be withdrawn prior to maturity or they can perhaps only be withdrawn with advanced notice and/or by having a penalty assessed. Sight deposits are deposits which can be withdrawn either without notice, or after a very short notice period.)

 

• Households’ net deposits into National Savings and Investment (NS&I) accounts decreased to -£0.8bn in January, from £0.6bn in December.

 

• Deposits into NS&I accounts are not captured within households’ deposits with banks and building societies, but can act as a substitute for them. Overall households’ deposits with banks and building societies, as well as NS&I accounts, grew by £6.0bn in January. This is more than the average monthly rate of £5.3bn over the past six months, but less than the £7.5bn observed in October 2023.

 

• The effective interest rate paid on individuals’ new time deposits with banks and building societies fell by 27 basis points, from 4.80% in December to 4.53% in January. The effective rate on the outstanding stock of time deposits increased by 5 basis points, from 3.71% in December to 3.76% in January. And the effective rate on stock sight deposits increased by 4 basis points from 2.03% in December to 2.07% in January.

 

• Individuals repaid, on net, £1.1bn of mortgage debt in January compared to £0.9bn in December. The annual growth rate for net mortgage lending was negative in January for the first time since the series began in March 1994, at -0.2%, a new series low. Gross lending decreased from £17.2bn in December to £16.9bn in January, and gross repayments also decreased from £19.0bn in December to £18.5bn in January.

 

• Net mortgage approvals for house purchases (that is, approvals net of cancellations), which is an indicator of future borrowing, rose from 51,500 in December to 55,200 in January, and net approvals for remortgaging (which only capture remortgaging with a different lender) increased from 30,800 in December to 30,900 in January.

 

• The ‘effective’ interest rate – the actual interest rate paid – on newly drawn mortgages fell by 9 basis points, from 5.28% in December to 5.19% in January. The rate on the outstanding stock of mortgages increased by 5 basis points, from 3.36% in December to 3.41% in January.

 

• Net borrowing on consumer credit by individuals rose to £1.9bn in January, up from £1.3bn in December. This was mainly driven by higher borrowing through credit cards, which rose from £0.3bn in December to £0.9bn in January. Net borrowing through other forms of consumer credit (such as car dealership finance and personal loans) also increased slightly, from £0.9bn in December to £1.0bn in January. The annual growth rate for all consumer credit increased, and is now at 8.9% in January (compared to 8.5% in December). This reflects a rise in the annual growth rate for other forms of consumer credit, from 6.8% in December to 7.4% in January. This increase was partially offset by credit card borrowing falling slightly, from 12.8% to 12.6%.

 

You can read the full BoE Money and Credit Statistical Release here.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

PENSIONS

 

HMRC Pension Scheme Newsletter 156 – February 2024

(AF8, FA2, JO5, RO4, AF7)

 

Pension scheme newsletter 156 covers the following:

 

• lifetime allowance abolition
• pension scheme return
• public service pensions remedy — tax treatment of interest

 

Areas of interest

 

Lifetime allowance abolition

 

HMRC confirm the Finance Bill 2023-24 has passed through the House of Lords and will shortly receive Royal Assent.  

 

Any amendments to the primary legislation will be made through regulations.

 

Public service pension remedy (aka McCloud rectification) – tax treatment of interest

 

The newsletter seeks to clarify the taxation of any interest paid as part of the remedy. The rate of interest that must be applied by the scheme is set at 8%.  This creates potential tax complications.  The tax treatment will differ depending on the reason the interest is being paid as set out below

 

Interest on Compensation

The interest on compensation paid under the Public Service Pensions and Judicial Offices Act 2022 is exempt from tax regardless of the interest rate it is paid at.

 

Interest on authorised pensions and lump sum payments

The arrears of pension will be taxable under PAYE (Pay As You Earn).

 

Interest payments applied to pension arrears will qualify as scheme administration member payments where the interest rate is no more than 1% above the Bank of England Base rate (commercial rate).  Where interest is provided at above this rate it will be an unauthorised payment.  As the interest rate applied must be 8% this will create some problems as this will clearly be higher.

 

Interest on authorised top-up lump sums

Where due to the member’s choice under the remedy value of their lump sum benefit has increased, the scheme is required to make a top-up lump sum payment. 

 

Lump sum and interest paid separately

Where the interest is paid as a separate payment to the top-up lump sum, it is treated in the same way as interest paid on pension arrears as described above.

 

Lump sum and interest payable within maximum limits

Interest paid on a top-up lump sum that is an authorised lump sum can be taxed in the same way as that lump sum if it is paid both:

• together with the top-up lump sum as one payment
• together with the original and top-up lump sums and it doesn’t exceed the maximum limit for the lump sum to remain an authorised payment

 

Lump sum and interest exceed maximum limits — scheme administration member payment

Where the single payment of the top-up lump sum and interest exceeds the maximum limit for the lump sum, then the excess is first considered against the scheme administration member payment conditions ie that the interest is payable at a commercial rate. 

 

Lump sum and interest exceed maximum limits — unauthorised payment

Where the remaining portion of the interest payment is in excess of a commercial rate of interest, that excess amount will be an unauthorised payment.

 

If part of the top-up lump sum is unauthorised, then the interest related to that unauthorised part will be an unauthorised payment and subject to the unauthorised payments charge.

 

The newsletter provides an example which may things clearer:

 

The member retired three years ago.  As a result of the member’s immediate choice a further £10,000 lump sum, that is a pension commencement lump sum, is due.  The scheme is required to pay 8% simple interest of £2,400 on this top-up lump sum. 

 

• The scheme makes a single payment of £12,400.
• The member’s maximum possible pension commencement lump sum is £11,500.
• From the £12,400 payment, £11,500 is classified as a pension commencement lump sum. 
• The remaining £900 needs to be considered against the payment conditions for a scheme administration member payment.
• The commercial rate of interest is identified by reference to the original £10,000 top-up lump sum. For example, if the commercial rate of interest was 2% for each of the three years, this would be £600.

 

The single payment of £12,400 is categorised and taxed as follows:

 

• pension commencement lump sum — £11,500
• scheme administration member payment — £600 (amount of interest payable at a commercial rate)
• unauthorised payment — £300 (interest payable in excess of a commercial rate)

 

Interest on unauthorised payments

To add further complication, interest on unauthorised payments is itself an unauthorised payment. Interest payments that are unauthorised payments should be reported to HMRC under the normal processes for unauthorised payments.

 

 

 

 

DWP Consultation: Options for Defined Benefit schemes

(AF8, FA2, JO5, RO4, AF7)

 

The DWP has published a consultation paper to introduce reforms to private sector DB pensions. The consultation proposes two main reforms:

 

• Access to DB surpluses: Proposals aim to “support schemes to invest for surplus in productive asset allocations by making it easier to share scheme surplus with employers and scheme members”. The Government says it will ensure that new flexibilities “do not threaten member security”.

 

• PPF to provide a DB consolidation option: As originally announced in November 2023, the Government intends to establish a public sector consolidator of private sector DB schemes, and to do so by 2026. The consultation paper confirms that this function will be carried out by the Pension Protection Fund (PPF) (which was previously an open question – at least officially). Although smaller and less well funded schemes would be the “primary targets”, some “larger or more complex schemes” may also enter.

 

In the consultation description, the DWP said that: “Although pension schemes are in surplus, under current legislation it is difficult and costly for many scheme trustees to share this upside with employers and scheme members.” Pensions Minister Paul Maynard said in the associated Press Release that: “We are in a welcome position with DB pension schemes enjoying high levels of funding, and we want to make this money work harder for savers and the wider economy. I welcome industry views on our plans to reform the pensions market.”  The consultation closes at 11:59pm on 19 April 2024.

 

Steve Webb, Partner at LCP, commented in their Press Release that: “It is welcome that the Government is moving forward with ideas about the better use of £1.4trn of assets held by DB schemes. The suggestion of a ‘statutory over-ride’ to make sure that all DB schemes in robust financial health could explore options around surplus extraction is a very positive one. But with regard to surplus extraction, we do not believe many trustees would be reassured if the only safeguard for members before money could be taken out was that the scheme was currently well-funded.”

 

Head of DB Actuarial Consulting at Hymans Robertson Laura McLaren said in their Press Release that: “We’re pleased the Government has supported our call to link conditions for surplus extraction to scheme funding level and security of accrued rights. We also welcome the proposal that extracting surplus will not be conditional on use of funds for particular purposes. Surplus extraction will be more effective where it is part of a larger reframing of the statutory objective for DB, to bring about a DB renaissance and secure future pension provision.”

 

 

 

 

 

 

PPI: How could a Lifetime Provider Model impact members, employers, and industry?

(AF8, FA2, JO5, RO4)

 

The Pensions Policy Institute (PPI) released a research report, How could a Lifetime Provider Model impact members, employers, and industry?

 

In 2023 the Government announced plans to explore options for multiple default consolidator vehicles, to manage small, deferred member DC pension pots, and proposed a Lifetime Provider Model, to prevent small deferred pots building up in the future. This report considers the potential impact of the Lifetime Provider Model on key stakeholders and explores policy implications for the wider market, Lifetime Provider policy infrastructure and how this policy could be sequenced alongside other policy agendas.

 

To support this report and the PPI’s response to the call for evidence, on January 15th 2024, the Pensions Policy Institute (PPI) facilitated a policy workshop, kindly hosted by the Association of British Insurers, to discuss proposed policy reforms relating to the Lifetime Provider Model. The policy workshop was attended by 50 people representing different stakeholder groups including members, industry, pension providers, and employers.

 

This report sets out the potential impact on key stakeholders of implementing a Lifetime Provider Model, what key stakeholders may need to consider if this policy were to be implemented and sets out the implications and trade-offs of different options.

 

 

ABI: 2023 sets new post-pension freedoms record for annuity sales

(AF8, FA2, JO5, RO4)

 

The Association of British Insurers (ABI) has issued a Press Release summarising their latest annuity data from their members. This shows that the value of total annuity sales in 2023 was £5.2bn, a 46% increase on 2022 and the highest annual value since 2014. The number of annuity contracts sold also increased last year to 72,200, up 34% on 2022, the largest number recorded since 75,000 were sold in 2016. The most popular version of the product remained the level-only annuities, which pay the same income every year but can be vulnerable to inflation, at 82% of the total number sold.

 

Rob Yuille, Head of Long-term Savings Policy at the ABI, is quoted as saying that: “Securing a guaranteed income for life remains an important part of the mix of options for people to consider at and during retirement, and it’s great to see more people taking advantage of the protection they have to offer. It is also encouraging to see more people exploring the market to secure a higher income. However, we’d like to see more people taking advantage of professional advice and new forms of targeted support for consumers to ensure they can enjoy the best possible retirement.”

 

 

 

 

TPR makes strategic shift in its oversight of the workplace pensions market

(AF8, FA2, JO5, RO4)

 

The Pensions Regulator (TPR) has announced, via a Press Release, details of organisational changes to reinforce its strategic shift in overseeing the workplace pensions market. TPR said that the pensions landscape is quickly evolving into a competitive marketplace of fewer, larger schemes which presents different risks and opportunities for savers and the economy. From April 2024, TPR will create three new regulatory functions which it said will protect, enhance and innovate in savers’ interests. The three new functions will be regulatory compliance; market oversight; and strategy, policy and analysis and TPR will be recruiting three new Executive Director roles in those areas. In the interim, from April 2024, there will be temporary appointments from within TPR. The new functions will be supported and enabled by essential functions: operations; digital; data and technology; and people.

 

TPR Chair Sarah Smart said: “We are moving from a fragmented pensions landscape of thousands of small schemes to an environment of fewer, larger schemes. That means we need to change our regulatory approach to protect savers in the future. The market should expect us to engage with it differently from now on. Our new structure means we will be swifter to address compliance failures and market-wide risks while being more dynamic in our industry engagement and bringing innovation to the fore.”

 

Nausicaa Delfas, TPR Chief Executive, added: “We have to make sure that workplace pensions work for savers. Our organisational changes are about bringing our talented and capable colleagues together to protect, enhance and innovate in savers’ interests.”